https://www.taxtmi.com/caselaws?id=30245 SC held that penalty under s.271(1)(c) may be levied even where the return shows a loss, applying the law as it stood on the date of filing. The Court explained that a returned loss can include current-year loss or carried-forward loss under s.72, so the applicable legal position is determined at filing. Explanation 4 to s.271(1)(c) is clarificatory, not substantive. The Division Bench decision in the earlier Virtual Soft case was overruled and the appeal was decided in favor of the revenue. en-us Mon, 18 Aug 2008 00:00:00 +0530 Mon, 03 Aug 2026 11:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=30245 SC held that penalty under s.271(1)(c) may be levied even where the return shows a loss, applying the law as it stood on the date of filing. The Court explained that a returned loss can include current-year loss or carried-forward loss under s.72, so the applicable legal position is determined at filing. Explanation 4 to s.271(1)(c) is clarificatory, not substantive. The Division Bench decision in the earlier Virtual Soft case was overruled and the appeal was decided in favor of the revenue. Case-Laws Income Tax Mon, 18 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=30245