Penalty under section 271(1)(a) upheld where the issue was already settled by earlier Supreme Court authority.

Penalty under section 271(1)(a) of the Income-tax Act was held to be applicable on the first question raised, because the issue had already been settled by an earlier Supreme Court decision and counsel accepted that position. The Court therefore answered the question in the affirmative and in favour of the Revenue, against the assessee.

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Issues: Whether the first question relating to the applicability of penalty under section 271(1)(a) of the Income-tax Act, 1961 stood concluded in favour of the Revenue.

Analysis: The answer to the first question had already been settled by the Court in an earlier decision, and counsel for the parties accepted that position. The question was therefore answered in the affirmative.

Conclusion: The first question was answered in favour of the Revenue and against the assessee.

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