1984 (2) TMI 36

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....or the assessment year 1967-68, during the assessment proceedings, the ITO noticed that the assessee had shown a cash credit of Rs. 15,000 in his account books in the name of one Sucha Singh of village Bhucho. The said Sucha Singh was produced by the assessee before the ITO. He stated that he had mortgaged seven acres of land situated in District Ferozepore in January, 1967, for a sum of Rs. 16,50....

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....dings and imposed a penalty of Rs. 15,000 on the assessee, vide his order dated March 20, 1975. The assessee went up in appeal, which was dismissed by the AAC. The assessee went up in appeal before the Tribunal, which allowed the appeal on the ground that, merely because the explanation given by the assessee had been disbelieved, no penalty could have been imposed upon him. The Commissoner of Inco....

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....lars. However, after April 1, 1964, the situation has been amended and the word "deliberately " has been deleted from s. 271(1)(c) of the I.T. Act, 1961. In a case arising after that period, a Division Bench of this court had considered a similar point in Jawahar Woollen Textile Mills v. CIT [1973] 92 ITR 510. Therein, the ITO had tried to ascertain from the available source whether the amount in ....