https://www.taxtmi.com/caselaws?id=14997 Filing of the audit report defeated the penalty under section 271B because the Tribunal found on the record that the assessee had already submitted it, making the levy unsustainable on facts. The Revenue's attempt to press a limitation point did not assist its case, as the High Court noted that the decisive factual issue had been overlooked by the lower authorities. The Court treated the continued pursuit of the reference as frivolous litigation and declined to entertain the application, thereby upholding deletion of the penalties for the relevant assessment years. en-us Thu, 29 Jul 1999 00:00:00 +0530 Mon, 27 Jul 2009 15:30:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14997 Filing of the audit report defeated the penalty under section 271B because the Tribunal found on the record that the assessee had already submitted it, making the levy unsustainable on facts. The Revenue's attempt to press a limitation point did not assist its case, as the High Court noted that the decisive factual issue had been overlooked by the lower authorities. The Court treated the continued pursuit of the reference as frivolous litigation and declined to entertain the application, thereby upholding deletion of the penalties for the relevant assessment years. Case-Laws Income Tax Thu, 29 Jul 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14997