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    <title>2001 (2) TMI 118 - DELHI High Court</title>
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    <description>Penalty under section 271(1)(c) turned on the crucial date on which the matter was referred to the Inspecting Assistant Commissioner, because a reference made before 1 April 1976 attracted a different penalty consequence from a later reference. The assessment had been reopened and completed under sections 147 and 148, but the Tribunal record did not contain a finding on that decisive date. The Delhi HC therefore sent the matter back to the Tribunal for reconsideration after ascertaining when the reference was made, since that fact determined whether the penalty could stand.</description>
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      <link>https://www.taxtmi.com/caselaws?id=14410</link>
      <description>Penalty under section 271(1)(c) turned on the crucial date on which the matter was referred to the Inspecting Assistant Commissioner, because a reference made before 1 April 1976 attracted a different penalty consequence from a later reference. The assessment had been reopened and completed under sections 147 and 148, but the Tribunal record did not contain a finding on that decisive date. The Delhi HC therefore sent the matter back to the Tribunal for reconsideration after ascertaining when the reference was made, since that fact determined whether the penalty could stand.</description>
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