1971 (3) TMI 29

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....aw under section 66(1) of the Indian Income-tax Act, 1922: " Whether, on the facts and in the circumstances of the case, the Tribunal rightly imposed a penalty of Rs. 3,000 under section 28(1)(c) of the Income-tax Act, 1922 ? " The reference relates to the assessment year 1947-48, the relevant previous year ending on March 31, 1947. The Income-tax Officer noticed a number of cash deposits in the....

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....ncome-tax Officer had not discharged the burden resting upon him to prove that the case called for the levy of a penalty. But, on appeal by the Income-tax Officer, the Tribunal came to a different view. The Tribunal held that no distinction could be drawn between the quantum of evidence required to support an assessment and the quantum of evidence required to justify the imposition of a penalty un....