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The High Court of Gujarat upheld a penalty of Rs. 22,097 imposed under section 271(1)(a) of the Income-tax Act, 1961, on an assessee for a delay of 23 months in filing the income tax return. The Appellate Assistant Commissioner and the Tribunal supported the penalty decision, citing lack of substantiating evidence for the delay explanation provided by the assessee. The Tribunal's decision was deemed correct, and the penalty was upheld.
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