https://www.taxtmi.com/caselaws?id=5585 Section 104 of the Income-tax Act was treated as quasi-penal, so the factual findings that no deliberate concealment or inaccurate particulars were established in penalty proceedings governed its application to the unexplained cash credit addition. On that factual basis, the amount could not be differently treated for section 104 purposes, and the matter did not raise a referable question of law under section 256(2). No reference was required. en-us Tue, 10 Jan 1995 00:00:00 +0530 Wed, 26 Nov 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5585 Section 104 of the Income-tax Act was treated as quasi-penal, so the factual findings that no deliberate concealment or inaccurate particulars were established in penalty proceedings governed its application to the unexplained cash credit addition. On that factual basis, the amount could not be differently treated for section 104 purposes, and the matter did not raise a referable question of law under section 256(2). No reference was required. Case-Laws Income Tax Tue, 10 Jan 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5585