1977 (8) TMI 1

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....als is a registered firm constituted by two brothers and their sons. It runs a restaurant called " Chandravilas Hotel " in Ahmedabad. For the assessment year 1967-68, it filed a return on September 2, 1967, disclosing an income of Rs. 34,131. It was, however, assessed for that year on a total income of Rs. 1,65,422. For the assessment year 1968-69, it returned an income of Rs. 68,841 but was asses....

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....,000 on the respondent in respect of the return filed for the assessment year 1967-68. A similar order was passed on December 9, 1970, levying a penalty of Rs. 2,12,000 for the assessment year 1968-69. The respondent then preferred appeals to the Income-tax Appellate Tribunal, which, by its judgments of March 18 and 20, 1972, set aside the orders of penalty. The Additional Commissioner of In....

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.... why we are unable to agree with the reasoning of the Tribunal, but any elaboration of the matter here is likely to prejudice the rights and contentions of the parties in the two appeals. It is, therefore, desirable, a course to which counsel have no objection, that if we are disposed to set aside the orders of the High Court and the Tribunal, we do so by a brief order. Accordingly, we direct t....