1996 (4) TMI 73

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....Act, 1961 (hereinafter referred to as "the Act"), referred the following question of law for the assessment year 1977-78 : " Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in cancelling the penalty of Rs. 15,218 imposed under section 271(1)(c) of the Income-tax Act, 1961 ? " As to what are the facts in the case we may refer a portion of paragraph 2 of t....

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....ncome-tax Officer started penalty proceeding under section 271(1)(c) of the Income-tax Act, 1961, and asked the assessee to explain as to why it should not be penalised. The assessee replied that the aforesaid difference arose merely because of difference of opinion between the assessee and the Income-tax Officer and so it should not be considered as a result of any concealment of income on the pa....