1986 (7) TMI 65

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....ax Appellate Tribunal, Allahabad Bench, has referred to this court for its opinion the following question : "Whether, on the facts and in the circumstances of the case, the Appellate Tribunal was legally justified in cancelling the penalty imposed by the Inspecting Assistant Commissioner after April 1, 1971 (1976 ?), i.e., on February 9, 1977 ?" The relevant assessment year in regard to the ....

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....ssistant Commissioner under section 274 of the Act. The Inspecting Assistant Commissioner held that the provisions of section 271 (1) (c) were attracted and imposed the penalty by order dated November 29, 1971. On appeal, the Tribunal held that as section 274(2) of the Income-tax Act had been amended with effect from April 1, 1971, by the Taxation Laws (Amendment) Act of 1970, the Inspecting Assis....