2008 (11) TMI 174

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.... the penalty levied under section 271(1) (c) of the Act on the ground that there was loss assessed in the year under consideration, without appreciating the fact that there was positive income which was reduced to nil only after allowing set off of carried forward losses of earlier years?" At the outset, learned counsel for the appellant (CIT) fairly admits that earlier in Tax Appeal No. 167 of 2....