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2001 (5) TMI 12

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....ion 256(2) of the Income-tax Act, 1961 (in short 'the Act"), the following question has been referred by the Income-tax Appellate Tribunal, Delhi Bench "A" (in short "the Tribunal"), for the opinion of this court: "Whether, on the facts and circumstances of the case, the Tribunal was justified in law in holding that the levy of penalty for concealment was correct?" In short the factual position....

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....e Appellate Assistant Commissioner as well as by the Tribunal. The assessee moved an application under section 256(1) of the Act for reference of a question, stated to be a question of law. The same having been rejected by the Tribunal, this court was moved and pursuant to the directions given by this court, the question as set out above has been referred for opinion. We have heard learned couns....