1983 (12) TMI 18

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....ions of law to this court for opinion: " 1. Whether, on the facts and in the circumstances of the case, and in view of the fact that the return of income was filed on June 29, 1965, the Tribunal was Tight in holding that the Explanation added to section 271(1)(c) of the Income-tax Act, 1961, by the Finance Act, 1964, with effect from April 1, 1964, could not be invoked in this case ? 2. Whet....

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....It may be observed that neither the ITO nor the AAC had found that the case of the assessee that, in fact, the books of account had not been closed and audited prior to the filing of the original return on July 31, 1964, (June 29, 1965 ?) was not believable. The findings of fact recorded by the Tribunal have not been challenged. In this application, the question of law referred to us for opinio....