https://www.taxtmi.com/caselaws?id=2873 SC held that, as enacted before the Finance Act, 2002, Section 271(1)(c) and Explanation 4 permitted penalty for concealment only where assessed income was positive and tax payable; therefore penalty could not be imposed when assessment showed a loss. The Court ruled the 2002 amendment (effective April 1, 2003) expanding penalty liability to assessments at loss is substantive and prospective, not retrospective. Appeals were allowed and the impugned judgment set aside consistent with this interpretation. en-us Tue, 06 Feb 2007 00:00:00 +0530 Tue, 16 Sep 2025 15:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=2873 SC held that, as enacted before the Finance Act, 2002, Section 271(1)(c) and Explanation 4 permitted penalty for concealment only where assessed income was positive and tax payable; therefore penalty could not be imposed when assessment showed a loss. The Court ruled the 2002 amendment (effective April 1, 2003) expanding penalty liability to assessments at loss is substantive and prospective, not retrospective. Appeals were allowed and the impugned judgment set aside consistent with this interpretation. Case-Laws Income Tax Tue, 06 Feb 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=2873