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| The Tax Publishers2022 TaxPub(DT) 5937 (Bang-Trib) INCOME TAX ACT, 1961
Section 254(1)
Assessee by way of additional ground of appeal challenged penalty under section 271AAA pleading that penalty under section 271AAA was not automatic and only upon non-satisfaction of the conditions specified under the said section penalty could have been levied. The being legal in nature, was admitted for adjudication.
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Appeal (Tribunal) - Additional ground - Admissibility - Legal issue
Assessee by way of additional ground of appeal challenged penalty under section 271AAA pleading that penalty under section 271AAA was not automatic and only upon non-satisfaction of the conditions specified under the said section penalty could have been levied. Held: Issue raised by assessee being legal issue necessiating no invetigation into the new facts as admitted for adjudication.
Followed:National Thermal Power Co Ltd v. CIT (1998) 229 ITR 383 (SC) : 1998 TaxPub(DT) 342 (SC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2008-09 & 2009-10
INCOME TAX ACT, 1961
Section 271AAA
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