1979 (2) TMI 146

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....d the assessment order, the appellate order of the AAC against that assessment, the penalty order, the grounds of appeal before the AAC and also the appellate order cancelling the penalty. We heard the departmental representative as well as the assessee. We have no hesitation to agree with the reasoning and conclusion of the AAC. So this appeal has to be dismissed. We fully endorse the reasoning a....

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....n items as income of the assessee, such non-satisfaction of the assessing authorities was on account of the fraud, gross or wilful neglect on the part of the assessee. So the Explanation is of no practical value in this case. 4. There is a marked difference and distinction between assessment and penalty proceedings. That has been correctly noticed and mentioned by the AAC. It is now well settled ....