Penalty jurisdiction under section 271(1)(c) required a supplementary statement of case to clarify the reference date.

The Tribunal's ability to answer the reference on the existing statement of case, and the relevance of the date on which penalty proceedings were referred to the Inspecting Assistant Commissioner for jurisdiction under section 271(1)(c) of the Income-tax Act, 1961, required clarification on the record. The High Court directed the Tribunal to furnish a supplementary statement of case specifying the date of reference of the penalty matter to the Inspecting Assistant Commissioner, and ordered the reference to be listed again for further hearing after receipt of that statement.

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Issues: Whether the Tribunal could determine the reference question on the existing statement of case, and whether the date of reference to the Inspecting Assistant Commissioner was material to the jurisdiction to impose penalty under section 271(1)(c) of the Income-tax Act, 1961.

Outcome: The Court directed the Tribunal to send a supplementary statement of the case stating the date on which the matter regarding imposition of penalty was referred to the Inspecting Assistant Commissioner, and ordered the reference to be fixed for further hearing after receipt of that statement.

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