Baiton Cables (P.) Ltd. vs Income-Tax Officer on 5 November, 1984
For this proposition, he relied on 110 ITR (Mad.) (sic). He also stated that the penalty having been levied after 1-4-1976, Explanation 1 to Section 271(1)(c) is attracted and, therefore, penalty has been rightly levied. For this, he relied on James Finlay & Co. Ltd. v. CIT [1983] 144 ITR 423 (Cal.).