https://www.taxtmi.com/caselaws?id=17355 The court addressed the interpretation of the Explanation to section 271(1)(c) of the Income-tax Act, 1961, focusing on its applicability to penalty proceedings initiated after its enactment but based on returns filed before that date. The court emphasized determining whether the Explanation constituted substantive or procedural law. The Tribunal's decision not to apply the Explanation in the penalty proceedings was challenged, leading to a directive for further examination. The judgment aimed to clarify the legal position on the retrospective application of the Explanation in penalty cases. en-us Mon, 04 Aug 1997 00:00:00 +0530 Mon, 21 Sep 2009 17:34:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17355 The court addressed the interpretation of the Explanation to section 271(1)(c) of the Income-tax Act, 1961, focusing on its applicability to penalty proceedings initiated after its enactment but based on returns filed before that date. The court emphasized determining whether the Explanation constituted substantive or procedural law. The Tribunal's decision not to apply the Explanation in the penalty proceedings was challenged, leading to a directive for further examination. The judgment aimed to clarify the legal position on the retrospective application of the Explanation in penalty cases. Case-Laws Income Tax Mon, 04 Aug 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17355