2006 (6) TMI 85

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....A3 disclosed a sum of Rs. 1,00,000 as loan from A4. Accordingly, the returns were filed by A1 to A3 for the assessment period 1986-87. The tax authorities conducted a search of the premises of A4 and found that there is no corresponding entry in the accounts of A4 to corroborate the loan of Rs. 1,00,000 to A1 to A3. A4 was not able to substantiate the source, hence he stated to the income-tax auth....

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....return at any time before the expiry of one year from the end of the relevant assessment year or before the completion of the assessment, whichever is earlier." The provisions of sections 276C, 277 and 278 read thus: "276C. Wilful attempt to evade tax, etc.-(1) If a person wilfully attempts in any manner whatsoever to evade any tax, penalty or interest chargeable or imposable under this Act,....

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....which shall not be less than three months but which may extend to three years and shall, in the discretion of the court, also be liable to fine. 277. False statement in verification, etc.-If a person makes a statement in any verification under this Act or under any rule made thereunder, or delivers an account or statement which is false, and which he either knows or believes to be false, or doe....

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....aded, if the declaration, account or statement had been accepted as true, or which is wilfully attempted to be evaded, exceeds one hundred thousand rupees, with rigorous imprisonment for a term which shall not be less than six months but which may extend to seven years and with fine; (ii) in any other case, with rigorous imprisonment for a term which shall not be less than three months but whic....