https://www.taxtmi.com/caselaws?id=8028 For penalty computation under section 271(1) read with section 271(2), a registered firm treated as unregistered for penalty purposes cannot reduce its tax liability by advance tax paid by the partners on their individual shares of profits. The statutory fiction in section 271(2) extends only to treating the firm as unregistered for determining penalty, and does not convert partners' advance tax payments into tax paid by the firm. Credit for advance tax belongs only to the assessee who actually paid it, and the firm and its partners remain separate assessees. The reference was answered against the assessee and in favour of the Revenue. en-us Wed, 28 Oct 1970 00:00:00 +0530 Fri, 27 Mar 2009 11:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8028 For penalty computation under section 271(1) read with section 271(2), a registered firm treated as unregistered for penalty purposes cannot reduce its tax liability by advance tax paid by the partners on their individual shares of profits. The statutory fiction in section 271(2) extends only to treating the firm as unregistered for determining penalty, and does not convert partners' advance tax payments into tax paid by the firm. Credit for advance tax belongs only to the assessee who actually paid it, and the firm and its partners remain separate assessees. The reference was answered against the assessee and in favour of the Revenue. Case-Laws Income Tax Wed, 28 Oct 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8028