2006 (4) TMI 518

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..... eby formulated : 1. Whether the Ld. ITAT was right in deleting penalty u/s 271(1)(c) of the Income Tax Act, 1961 on the ground that the total income of the assessee has been assessed at a minus figure/loss? 2. Whether the Ld. ITAT was justified in holding that the judgments in Prithipal Singh's case (183 ITR 69 and 249 ITR 670) will apply even after insertion of Explanation 4 to Section .....

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..... ?concealed the particulars of his income or furnished inaccurate particulars of such income.? Nor did it examine the quantum of penalty in each case. The ITAT decided the appeals before it on the understanding that where there was a returned loss and a reduced loss was assessed there could be no question of imposition of penalty under Section 271(1)(c) of the Act. This understanding, we have indi .....

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