1977 (6) TMI 59

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... The assessee was called upon to pay advance tax under s. 210 which was paid. He filed a return admitting an income of Rs. 50,746. The ITO noticed that upward revision under s. 212(3A) was not filed. He initiated penalty proceedings. The assessee's case was that the only source of income was share income, the firm did not close its accounts and the assessee could not ascertain the share of profit....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... estimate the ITO had also issued a show cause notice as to why a penalty under s. 221(1) should not be levied. Where an assessee files an estimate no penalty can be levied on the ground that no estimate was made. According to the estimate the income was Rs. 53,300. Where an estimate had been filed but no tax is paid the assessee can be penalised under s. 221(1) and the provisions of s. 273(c) are....