2000 (10) TMI 29

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....t to an order dated November 22, 1979, in I. T. C. No. 51 of 1978 under section 256(2) of the Income-tax Act, 1961 (in short "the Act"), Income-tax Appellate Tribunal, Delhi Bench-D (in short "the Tribunal"), has referred the following question for the opinion of this court : "Whether, on the facts and in the circumstances of the case and having regard to the fact that the assessee agreed to be....

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....ted penal proceedings and imposed penalty. In appeal, the Appellate Assistant Commissioner upheld the decision of the Assessing Officer. The matter was carried in appeal before the Tribunal which held that merely because there was an agreement for assessment at a particular figure that did not per se bring in the concept of concealment. On the mer its it was held that the Revenue did not prove con....