Income Tax Tribunal's Findings Protect Appellants from Criminal Trial for Late Tax Filing u/s 254.

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....Criminal proceedings - late filing of return of income (ITR) - The appellants cannot be made to suffer and face the rigorous of criminal trial when the same cannot be sustained in the eyes of law because the entire prosecution in view of a conclusive finding of the Income Tax Tribunal that there is no concealment of income becomes devoid of jurisdiction and under Section 254 of the Act, a finding of the Appellate Tribunal supercedes the order of the AO - HC....