https://www.taxtmi.com/caselaws?id=15326 In penalty proceedings under s. 271(1)(c) of the IT Act, the HC held that findings in assessment proceedings are evidentiary but not conclusive; the assessee may dispute them in penalty proceedings where they affect penalty liability or quantum. However, the assessee's challenge to the validity of reassessment on the ground that the s. 148 notice did not provide 30 clear days was rendered academic due to retrospective statutory amendment; no relief could be granted on that basis. Consequently, the HC answered the substantive question in favour of the Revenue and upheld the Tribunal's confirmation of penalty under s. 271(1)(c). en-us Wed, 29 Sep 1999 00:00:00 +0530 Thu, 01 Jan 2026 12:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15326 In penalty proceedings under s. 271(1)(c) of the IT Act, the HC held that findings in assessment proceedings are evidentiary but not conclusive; the assessee may dispute them in penalty proceedings where they affect penalty liability or quantum. However, the assessee's challenge to the validity of reassessment on the ground that the s. 148 notice did not provide 30 clear days was rendered academic due to retrospective statutory amendment; no relief could be granted on that basis. Consequently, the HC answered the substantive question in favour of the Revenue and upheld the Tribunal's confirmation of penalty under s. 271(1)(c). Case-Laws Income Tax Wed, 29 Sep 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15326