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1997 (10) TMI 87 - AT - Income Tax
Extract:
.......ater period the ratio of those decisions is otherwise not applicable. 21. Having considered all the facts and circumstances of the case we are of the opinion that it is not a fit case for levy of penalty under s. 271(1)(c) both on facts and law and accordingly the same is directed to be cancelled. 22. In the result the assessee s appeal is allowed.