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Commissioner Of Income-Tax vs Prithipal Singh And Co. on 3 November, 1988

In CIT v. Prithipal Singh and Co. [1990] 183 ITR 69, the Punjab and Haryana High Court held that the income as envisaged in Section 271(1)(c) means positive income. If the loss declared has been reduced penalty under Section 271(1)(c) cannot be levied. This decision is in respect of the assessment year 1970-71, i.e., before the insertion of the above Explanation and hence cannot help the case of the assessee.
Punjab-Haryana High Court Cites 7 - Cited by 31 - Full Document

Commissioner Of Income Tax, Madras vs M/S. Khoday Eswarsa & Sons on 22 September, 1971

8. Reliance was placed on the decision given in the case of CIT v. Khoday Eswaraa and Sons , where the Supreme Court has observed that no doubt the original assessment proceedings for computing the tax may be a good item of evidence in the penalty proceedings ; but penalty cannot be levied solely on the basis of the reasons given in the original order of assessment. So far as this contention is concerned we feel that the evidence which is recorded in the assessment proceedings by itself will not be a conclusive evidence and the assessee is free to dispute the same in the penalty proceedings if it affects the liability for penalty or the quantum thereof. In the present case, the dispute was raised that the notice which was issued under Section 148 has not given 30 clear days. This plea has become only academic now because the provisions have been amended retrospectively. Therefore no relief in that behalf can be granted to the assessee.
Supreme Court of India Cites 9 - Cited by 234 - C A Vaidyialingam - Full Document

Commissioner Of Income Tax (Central) ... vs Harprasad & Co. (P) Ltd on 25 February, 1975

5. Earlier the penalty was with reference to the actual concealed income or tax thereon. The word "income" has been defined under Section 2(24) of the Act which is an inclusive definition. Section 4 is the charging section which creates the liability of tax on total income. The word "income" includes loss also (CIT v. Harprasad and Co. P. Ltd. ).
Supreme Court of India Cites 29 - Cited by 191 - R S Sarkaria - Full Document
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