1982 (7) TMI 151

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....nbsp;           This appeal has been preferred by assessee against order dt.21st Sept., 1981of the AAC of IT. 2. 1973-74 is the assessment year concerned. Financial year is the previous year. Assessee is a registered firm consisting of three partners. Assessment was completed by the ITO as per order dt.18th Feb., 1974determining total income ....

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.... as to genuineness of the credit in question. 3. Assessee went in appeal against the said assessment. Appellate Commr., however, declined to entertain the appeal on the footing that the same was time barred. There the matter rested so far as the quantum was concerned. 4. While completing the assessment, ITO initiated against the assessee proceedings for penalty for concealment of income to t....

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....it production of additional evidence. 7. In the second round of litigation ld. AAC again confirmed the penalty and dismissed the assessee's appeal. 8. Hence this appeal by the assessee. Assessee's contention was that Gopi Ram was not conversant with English language and that in the affidavit dt.22nd December, 1973, the date of loan came to be wrongly put as10th December, 1972. We see ample f....