2007 (4) TMI 255

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.... During the relevant assessment year, i.e., before the assessment year 1977-78, there was an Explanation below section 271(1) (c) which provided that where the declared income was less than 80 per cent. of the assessed income there was a presumption of concealment which could be rebutted by the assessee by showing absence of fraud or gross or wilful neglect in his part. 3. For the assessment ye....

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....observation: "However, these observations only show disbelief and they do not show that the contentions raised by the assessee were false." 6. The above observation of the Tribunal are beyond our comprehension. Once it has been said that the assessee is putting up a got up or cooked up story, how could it be said by any rational person that the contention of the assessee had not been found f....