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13. Moreover, in view of the judgement of of Apex Court in the case of The Institute of Chartered Accountants of India Vs. Vimal Kumar Surana and another (supra), the Supreme Court has dealt with the said issue and in this regard para 16 to 21 are relevant which are quoted hereinbelow :-

"16. In T.S. Baliah's case, the Court considered the question whether the appellant could be simultaneously prosecuted under Section 177 IPC and for violation of Section 52 of the Income Tax Act, 1922. After noticing Section 26 of the General Clauses Act, the Court held: