25 results for “disallowance”+ Section 271(1)(d)clear
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In the result, both the appeals are allowed
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
d) That the Ld CIT (Appeals), failed to appreciate that the assessment was framed under section 144 of the Income Tax Act and disallowance was made on technical grounds and the appellant is not guilty of concealment or furnishing of inaccurate particulars of income, therefore, the penalty under section 271(1