1997 (1) TMI 46

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.... order dated December 15, 1984, annexure-6 to the writ petition passed by the Chief Commissioner of Income-tax, Lucknow, under section 273A of the Income-tax Act, 1961 (briefly " the Act ") in so far it relates to the assessment year 1977-78. The facts, as briefly stated, are that return for the assessment year 1977-78 became due on June 30, 1997, but that was filed by the petitioner on Septemb....

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....assessing authority accepted the explanation of the assessee partially that the petitioner would have saved from agricultural income to the extent of Rs. 1,000 and Rs. 2,000 from past savings of the business income. So that explanation was accepted only to the extent of Rs. 3,000 and an addition for the unexplained amount of Rs. 5,000 was made. The Commissioner took the view that since the additio....

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....hen he furnished voluntarily the return making the disclosure of his net wealth. The submission of learned counsel for the petitioner is that addition on account of unexplained investment may have been made in the assessment, but the petitioner to its honest belief made full and true disclosure at the time when the return was filed. There is no finding by the Commissioner that the disclosure wa....