https://www.taxtmi.com/caselaws?id=25949 The High Court found the Tribunal's approach erroneous in determining the assessee was not guilty of fraud or gross neglect, emphasizing the burden of proof on the assessee despite income estimation. Regarding the cancellation of penalties under section 271(1)(c), the High Court disagreed with the Tribunal's decision, highlighting the legal fiction created by the Explanation to the section. The High Court concluded that the Tribunal's order was erroneous and directed the Tribunal to adjust its decision accordingly under section 260(1) of the Act. en-us Fri, 28 Mar 1986 00:00:00 +0530 Mon, 01 Feb 2010 18:18:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25949 The High Court found the Tribunal's approach erroneous in determining the assessee was not guilty of fraud or gross neglect, emphasizing the burden of proof on the assessee despite income estimation. Regarding the cancellation of penalties under section 271(1)(c), the High Court disagreed with the Tribunal's decision, highlighting the legal fiction created by the Explanation to the section. The High Court concluded that the Tribunal's order was erroneous and directed the Tribunal to adjust its decision accordingly under section 260(1) of the Act. Case-Laws Income Tax Fri, 28 Mar 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25949