COMMISSIONER OF INCOME TAX Vs. S.GOWRI

JUDGEMENT

(1.) Revenue has filed these Appeals under Section 260A of the 2 / 13 Income Tax Act, in short, ''Act'', aggrieved by the common order passed by the learned Income Tax Appellate Tribunal, for brevity, ''Tribunal'', dated 12.12.2013, setting aside the penalty under Section 271 (1) (c) of the Act against the Assessee, namely, Smt.S.Gowri, wife of late Sri S.Shanmugam, who expired on 23.01.2011.

(2.) The following Substantial Question of Law arises for consideration of this Court :

(3.) A search was conducted at the residence of Sri S.Shanmugam on 13.02.2009 and the learned Tribunal, by the order impugned, dated 12.12.2013, upheld the imposition of penalty against the said assessee, with the following observations :