1991 (1) TMI 76

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....ction 256(2) of the Income-tax Act, 1961, the Tribunal has stated the following question for our opinion : "Whether, on the facts and in the circumstances of the case, there was any material to support the finding that the assessee believed that he was under no statutory obligation to file a return and whether, under all the facts and circumstances of the case, the explanation of the assessee c....

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....and brought them to tax. Proceedings were taken both under clause (c) of sub-section (1) of section 271 as well as under clause (a) of sub-section (1) of section 271 against the assessee. It appears that the proceedings under section 271(1)(c) were concluded earlier. It was found in those proceedings that the assessee had not concealed any income nor had he furnished any inaccurate particulars.....