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Commissioner Of Income-Tax vs Lawly Enterprises (P.) Ltd. on 23 August, 1996

In the case of ITO v. Law Enterprises (1990) 185 ITR 595 (AP), the Andhra Pradesh High Court, by referring to provisions of section 269SS, where the expression used is "person is liable for penalty" has held that the word "liable" used in the section gives discretion to the court with regard to the imposition of fine or penalty. The court may either choose or impose fine or may dispense with the imposition of fine. When such discretion exists with regard to the imposition of fine itself, it could not be said that the court has no discretion with regard to the quantum of fine to be imposed. Thus, mere default or non-compliance with the provisions of section 269SS would not automatically attract the penalty under section 271D.
Patna High Court Cites 18 - Cited by 8 - Full Document
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