https://www.taxtmi.com/caselaws?id=799523 Penalty liability under Section 271(1)(c) for periods before 1 April 2016 requires application of Circular No. 25/2015 rather than automatic reliance on Explanation 4. The Circular treats the relevant explanation as prospective and makes penalty following an adjustment to computed income dependent on the nature of that adjustment. Where this framework was not considered, the penalty order and consequential demand notice were quashed, and the penalty liability was remitted for reconsideration under the Circular. en-us Wed, 02 Sep 2026 00:00:00 +0530 Wed, 23 Sep 2026 08:48:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799523 Penalty liability under Section 271(1)(c) for periods before 1 April 2016 requires application of Circular No. 25/2015 rather than automatic reliance on Explanation 4. The Circular treats the relevant explanation as prospective and makes penalty following an adjustment to computed income dependent on the nature of that adjustment. Where this framework was not considered, the penalty order and consequential demand notice were quashed, and the penalty liability was remitted for reconsideration under the Circular. Case-Laws Income Tax Wed, 02 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799523