2001 (8) TMI 53

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....ct, 1961. For the assessment year 1994-95, as against the returned income of Rs.4,08,950, the assessment was completed on a total income of Rs.8,72,302. Proceedings under section 271(1)(c) were initiated and Rs.2,66,427 was imposed as penalty. The assessee questioned the imposition of penalty on the ground that it had surrendered its income for addition to buy peace and tranquility and there wa....

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....earned counsel for the Revenue submitted that there is no material on record to show that there was any conditional offer for addition to the returned income. On the contrary, in view of the assessee's admission that he was not in a position to substantiate the claims for expenses, the accounts were rejected and the net profit rate was applied to the admitted receipts. The proceedings were initiat....