COMMISSIONER OF INCOME TAX Vs. PUSHPA DEVI JAIN

JUDGEMENT

(1.) The Income Tax Appellate Tribunal, Allahabad has referred the following question of law under Section 256 (1) of the Income Tax Act, 1961 (hereinafter , referred to as "the Act") for opinion to this Court.

(2.) The reference relates to the Assessment Year 1982-83 and 1983-84 in proceeding arising out of imposition of penalty under Section 271(1)(b) of the Income Tax Act, 1961..

(3.) Briefly stated, the facts giving rise to the present reference are as follows.