TMI Blog1979 (1) TMI 96X X X X Extracts X X X X X X X X Extracts X X X X ..... d to as "the Act"), the Commissioner of Income-tax, Amritsar-I, has prayed that the Income-tax Appellate Tribunal, Amritsar Bench (hereinafter referred to as the Tribunal), be directed to refer the following two questions of law to this court for decision: "(1) Whether, on the facts and in the circumstances of the case, the Tribunal has misdirected itself in holding that the claim made by the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ting to the electric fans. (4) Rs. 25,111 "reserve for bonus." The ITO also initiated penalty proceedings and he referred the case to the IAC under s. 274(2) of the Act. The IAC, after hearing the assessee, imposed a penalty of Rs. 24,925 in terms of the Explanation to s. 271(1)(c) of the Act. This order was assailed by the assessee before the Tribunal. The Tribunal accepted the appeal and r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the Tribunal. The revenue accepted the position regarding items Nos. 1 to 3 referred to in the earlier part of the judgment that the said items were a claim bona fide made which was disallowed by the ITO and thus no penalty proceedings could be taken. As regards item No. 4, the reserve for bonus, it is not disputed that this amount was shown in the balance-sheet attached with the return and thu ..... X X X X Extracts X X X X X X X X Extracts X X X X
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