In Brief
The assessee challenged the High Court's decision allowing the Revenue's appeal against deletion of a penalty under Section 271(1)(c) of the Income Tax Act. The assessee argued the Revenue's appeal was not maintainable because the penalty had been reduced to Rs.6,00,000/-, below the Rs.20,00,000/- threshold set by CBDT Circular No.21 of 2015. The Supreme Court held that maintainability must be assessed based on the original penalty amount (Rs.29,02,743/-) that was actually under challenge before the Tribunal and High Court, not subsequent reductions. The appeal was dismissed accordingly.">
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