1990 (8) TMI 26

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.... following two questions as questions of law under section 256(1) of the Income-tax Act, 1961 : "1. Whether, on the facts and in the circumstances of the case, the penalty orders passed by the Inspecting Assistant Commissioner under section 271 (1)(c) read with section 274(2) of the Act were without jurisdiction ? (2) Whether, on the facts and in the circumstances of the case, the penalty orders....

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....al or in the statement of the case as to the date of reference by the Income-tax Officer to the Inspecting Assistant Commissioner under section 274(2). As stated earlier, this is the material date with reference to which it can be decided whether or not the order of the Inspecting Assistant Commissioner imposing penalty was valid. Mr. Jetley, learned counsel for the Department, made an attempt to....