1997 (1) TMI 137

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....1(1)(c) of the IT Act, 1961, and relate to the asst. yrs. 1982-83 to 1984-85. 2. We have heard the rival submissions in the light of material placed before us and the precedents relied upon. The assessment order for the relevant assessment years were completed. Search action under s. 132 of the Act was conducted at the premises of the assessee, in the course of which some material was found whi....

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....bears eloquent testimony to the fact that the income offered was the concealed income of the assessee and it was reflected in the return because of the lurking fear of detection. 4. We find that the assessee agreed to surrender the income by incorporating the additional income in the returns which got subsequently regularised under s. 148. The apex Court in the case of Sir Shadilal Sugar & Gene....

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....bject to buy peace. Assessee was not inclined to drag the matter in the labyrinth of law. We find that the Department did not sufficiently prove the factum of concealment by independent enquiry. Addition is based solely on the basis of admission made by the assessee. It was also alleged by Shri Ranka, the learned counsel for the assessee that no incriminating material having nexus with the years u....

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....ld knowledge". The offence of concealment is thus a direct attempt to hide an item of income or a portion thereof from the knowledge of the IT authorities. It is implict in the word "concealed" that there has been a deliberate act on the part of the assessee. The meaning of the word "concealment" as found in Shorter Oxford English Dictionary, 3rd Edn., Vol. 1 is as follows: "In law, the inte....