https://www.taxtmi.com/caselaws?id=18572 Jurisdiction to impose penalty under section 271(1)(c) depended on whether the reference to the Inspecting Assistant Commissioner was made before 1 April 1976. If the reference pre-dated that amendment, the authority could complete the penalty proceedings after the change in law; however, the record did not show when the reference was made. Because that date was a necessary factual finding, the jurisdictional issue could not be resolved on the existing material. The matter was therefore remanded to the Tribunal to determine the date of reference and decide the case afresh in light of the governing precedent. en-us Fri, 19 Jan 1996 00:00:00 +0530 Thu, 01 Oct 2009 16:42:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18572 Jurisdiction to impose penalty under section 271(1)(c) depended on whether the reference to the Inspecting Assistant Commissioner was made before 1 April 1976. If the reference pre-dated that amendment, the authority could complete the penalty proceedings after the change in law; however, the record did not show when the reference was made. Because that date was a necessary factual finding, the jurisdictional issue could not be resolved on the existing material. The matter was therefore remanded to the Tribunal to determine the date of reference and decide the case afresh in light of the governing precedent. Case-Laws Income Tax Fri, 19 Jan 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18572