2018 (2) TMI 1991

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ent of income / furnishing of inaccurate particulars , without particularizing the nature of breach evidencing non application of mind? - HELD THAT:- As Revenue objects to question no.(ii) being admitted, as he states that this issue was not urged before the Tribunal. Prima facie, we are of the view that this is an issue of jurisdiction. Therefore, it could be raised before us as it goes to the ro .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... d : (i) Whether on the facts and circumstances of the case, the Tribunal was justified in upholding the imposition of penalty under Section 271(1)(c) of the Act with reference to addition of gift which were clearly disclosed in the original return of income? (ii) Whether on the facts and circumstances of the case, the entire proceedings for penalty under Section 271(1)(c) of the Act are rend .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X