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2004 (2) TMI 34 - HC - Income TaxPenalty u/s 271(1)(c) - entire undisclosed income in respect of which penalty has been imposed had been disclosed in the return filed by the assessee voluntarily on March 7,1991. Assessment on the basis of this return was framed under section 143(1) of the Act on March 11, 1991. No penalty proceedings had been initiated at that time. Once the entire amount stood assessed, there was no scope for issue of a fresh notice under section 148 to assess the same income once again. - There was, thus, no additional income assessed vide order dated March 7, 1994, warranting notice u/s 271(1)(c)
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