Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal's finding on it could not be converted into a substantial question of law under section 260A. As the Revenue's challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.
The determinative issue was whether the Assessing Officer had made the enquiry required before the Principal Commissioner invoked revision under section 263. The High Court treated that enquiry question as a pure question of fact, and held that the Tribunal's finding on it could not be converted into a substantial question of law under section 260A. As the Revenue's challenge depended on whether assessment proceedings were conducted with or without enquiry, the appeal was not entertainable on the basis urged and was rejected.
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