1972 (5) TMI 2

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....tion 271(c) read with the Explanation thereto ? " The assessee is a firm of two partners. This firm took over the business of another firm in which the partners of the assessee-firm were also partners. The business was one of processing and exporting of prawns. The assessee filed its return for the assessment year 1964-65 showing an income of Rs. 2,785.47. In arriving at this income the closing stock of the business had been valued at Rs. 7.03,123. The assessee had worked out the cost per pound on the basis of the total cost of production divided by the total quantity of raw materials. The Income-tax Officer took the view that there was under-valuation of the closing stock as, according to him, the closing stock should be valued on the b....

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....ection 271(1)(c), together with the Explanation, reads as follows : " 271. (1) If the Income-tax Officer or the Appellate Assistant Commissioner, in the course of any proceedings under this Act, is satisfied that any person ... (c) has concealed the particulars of his income, or furnished inaccurate particulars of such income, he may direct that such person shall pay by way of penalty,-... (iii) in the cases referred to in clause (c), in addition to any tax payable by him, a sum which shall not be less than, but which shall not exceed twice, the amount of the income in respect of which the particulars have been concealed or inaccurate particulars have been furnished. Explanation--Where the total income returned by any person ....