1991 (6) TMI 39

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....g Assistant Commissioner is as stated below : "Therefore, after the amendment, the concealed income is not mechanical or arithmetical difference between the income finally assessed and the income returned by the assessee. I have already pointed out that the concealed income or income in respect of which the assessee furnished inaccurate particulars is Rs. 62,755 and the reduction allowed by the Appellate Assistant Commissioner in respect of the veethapalisa does not in any way affect this concealment In this view of the matter, I hold that the assessee concealed particulars of his income or furnished inaccurate particulars in respect of a sum of Rs. 62,755. The assessee has absolutely no defence for this concealment and it cannot be deni....

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....nclusion that the concealed income is only Rs. 5,500, we are of the view that the Tribunal has committed an error and, therefore, the same is not sustainable. A reference in this connection to Division Bench ruling of this court in CIT v. India Sea Foods [1976] 105 ITR 708, is profitable. In that decision, the Division Bench was construing section 271(1)(c) as it stood then. For easy reference, we shall read the section : "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 penal....