2004 (9) TMI 65

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....of law under section 256(1) of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), for the opinion to this court: "Whether, on the facts and circumstances of the case, the Tribunal was right in law in upholding the levy of penalty to the tune of Rs. 23,000?" We have heard Shri Vikram Gulati, learned counsel for the assessee, and Shri A.N. Mahajan, learned standing counsel for th....