143 results for “penalty u/s 271”+ Section 2(14)(iii)clear
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14. The observations made by the Tribunal, at the outset, in our opinion, are based on surmise and conjecture. The Tribunal lost sight of the fact that the assessee being the lessor was owner of the rolls. Merely because, lessee had taken responsibility of selection of rolls and its transportation to Bellary, it would not be correct to state that