COMMISSIONER OF INCOME TAX Vs. S KRISHNASWAMY

JUDGEMENT

(1.) THE common questions referred to this court in these two tax case references, preferred by the Revenue are as follows

(2.) WHETHER, on the facts and in the circumstances of the case, the Appellate Tribunal was justified and had valid material in holding that for the default committed by the accountant, penalty under section 271 (1) (c) could not be levied "