G.D.AGRAWAL, P.MOHANARAJAN
Assistant Commissioner of Income-tax – Appellant
Versus
Maheshwari & Maheshwari – Respondent
Per Shri P. Mohanarajan, Judicial Member - All the aforesaid appeals are by the revenue directed against the order of the ld. CIT(A), Jabalpur and the cross-objections are by the assessee. The facts in all these appeals are not only identical but also one and the same. Hence this consolidated order is passed for the sake of convenience.
2. We have heard the ld. D.R. and the ld. counsel for the assessee. We have perused the records of these appeals. The issue relates to imposition of penalty under section 271(1)(c) of the Income-tax Act. For the assessment years 1977-78 to 1980-81, the returns were filed on 30-9-1977, 30-9-1978, 28-9-1978 and 10-9-1980 and assessments were completed on 30-8-1978, 2-12-1978, 8-3-1982 and 19-2-1983 respectively. The assessee was a partnership firm consisting of Shri Krishna Murari Gattani, Shri Brij Mohan Gattani and two others during the relevant period. On 12-5-1981, the Income-tax Department Officials conducted search operations at the premises of one Shri Naraindas Gattani (Now late), who was the father of the first two partners of the firm, and seized certain documents pertaining to the firm wherein some daily transactions were recorded. Simi
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