2006 (4) TMI 518

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....llowing two substantial questions of law arise for consideration and are hereby formulated : 1. Whether the Ld. ITAT was right in deleting penalty u/s 271(1)(c) of the Income Tax Act, 1961 on the ground that the total income of the assessee has been assessed at a minus figure/loss? 2. Whether the Ld. ITAT was justified in holding that the judgments in Prithipal Singh's case (....

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....estion in each case so as to return a positive finding of fact that the assessee in each case had ?concealed the particulars of his income or furnished inaccurate particulars of such income.? Nor did it examine the quantum of penalty in each case. The ITAT decided the appeals before it on the understanding that where there was a returned loss and a reduced loss was assessed there could be no quest....