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2005 (2) TMI 72 - HC - Income Tax
Penalty under section 271E – findings recorded by the Commissioner of Income-tax (Appeals) and the Tribunal that the assessee had shown reasonable cause for the failure to comply with the provisions of section 269T of the Act is a finding of fact based on appreciation of material on record. It does not give rise to any question of law, much less substantial question of law - Tribunal was right in law in dismissing the appeal of the Department and uphold the action of the Commissioner of Income-tax (Appeals) in cancelling the order of penalty under section 271E