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2004 (12) TMI 325 - ITAT DELHI-G
Extract:
.......er dt. 23rd Feb., 1998, referred to above. Thus, on the basis of rule of consistency also the Department was not justified in imposing penalty in this year. 30. In view of the above, we uphold the order of the learned CIT(A), and reject the grounds taken by the Revenue in this appeal. 31. In the result, the appeal filed by the Revenue is dismissed.