https://www.taxtmi.com/caselaws?id=25006 The High Court held that for penalty calculation under section 271(1)(c) of the Income-tax Act, the taxable income after deductions should be considered, not the gross capital gains. It ruled in favor of the assessee, stating that the penalty should be based on the assessed taxable income of Rs. 2,200, not the total capital gains of Rs. 9,000. The Court emphasized that interpretations favoring the taxpayer should be adopted in cases of ambiguity, particularly in penalty provisions. Consequently, the Tribunal was not justified in imposing a penalty of Rs. 9,000 when the additional tax assessed was only on an income of Rs. 2,200. en-us Tue, 10 Nov 1987 00:00:00 +0530 Sat, 23 Jan 2010 17:23:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25006 The High Court held that for penalty calculation under section 271(1)(c) of the Income-tax Act, the taxable income after deductions should be considered, not the gross capital gains. It ruled in favor of the assessee, stating that the penalty should be based on the assessed taxable income of Rs. 2,200, not the total capital gains of Rs. 9,000. The Court emphasized that interpretations favoring the taxpayer should be adopted in cases of ambiguity, particularly in penalty provisions. Consequently, the Tribunal was not justified in imposing a penalty of Rs. 9,000 when the additional tax assessed was only on an income of Rs. 2,200. Case-Laws Income Tax Tue, 10 Nov 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25006