Expenses on foreign training expenses incurred on prospective employee who joined the company thereafter was disallowed u/s143(3) which was subsequently set aside u/s250 by commissioner(appeals) and same was disallowed by the tribunal. The assessee filed an appeal in High Court which was admitted on the substantial question of law and submitted the same to AO. In the meantime AO passed an order u/s271(1)(c) stating that since case will be barred by limitation (six month from date of order of tribunal)...passed an order imposing penalty.
Please advice relevant case laws for filing appeal against order u/s271(1)(c)
High Court reviews penalty under Section 271(1)(c) for disallowed foreign training expenses; appeal seeks relevant case laws. A query was raised regarding a penalty imposed under Section 271(1)(c) of the Income Tax Act. The issue involved expenses on foreign training for a prospective employee, which were initially disallowed under Section 143(3), then set aside by the commissioner (appeals) under Section 250, but subsequently disallowed by the tribunal. The assessee appealed to the High Court, which admitted the case on a substantial question of law. Meanwhile, the Assessing Officer imposed a penalty, citing the case's impending limitation period. The discussion seeks advice on relevant case laws for appealing the penalty order. (AI Summary)
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