2006 (9) TMI 102

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.... preferred by the revenue proposing following substantial question of law : "Whether, on the facts and in the circumstances of the case, the Ld. Income-tax Appellate Tribunal was right in law in upholding the deletion of penalty under section 271E by the Commissioner of Income-tax (Appeals) on the ground that the assessee company was under bona fide belief that limit of Rs.20,000 for accepting a ....

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....sed by the then Deputy Commissioner of Income-tax, Range I, Jalandhar at Rs.10,000 vide order passed by him on October 21,1991. 3. On appeal, the Commissioner of Income-tax (Appals) Jalandhar deleted the said penalty vide his order passed in appeal No.700/91-92/CIT(A)/Jal., on November 16, 1992, holding that its imposition was not justified. The said order was affirmed by the Tribunal. 4. The Co....