1993 (1) TMI 21

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....n 261 of the Income-tax Act, 1961, for leave to appeal to the Supreme Court from the judgment in Income-tax Reference No. 287 of 1982 (CIT v. Bharath Sea Foods [1992] 195 ITR 60 (Ker)). At the instance of the Revenue, the following question came up for consideration in Income-tax Reference No. 287 of 1982 (see [1992] 195 ITR 60, 61) : "Whether, on the facts and in the circumstances of the case ....

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....llate Tribunal. This court held that the Appellate Tribunal has misdirected itself in law in reducing the penalty imposed by the Inspecting Assistant Commissioner from the amount of Rs. 1,05,000 to Rs. 47,000. The Appellate Tribunal had relied on materials which were not relied on by both sides. It was not the case of the assessee nor that of the Department that the opening balance in the ledger d....