1979 (8) TMI 69

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....t year 1964-65, the assessee, a partnership-firm dealing in yarn, returned an income of Rs. 21,600. During the assessment proceedings, the ITO found numerous mistakes and discrepancies in the assessee's books. Certain purchases had not been accounted for. After receipt of the assessee's explanation and on the basis of the same he recast the trading account and computed the total income at Rs.83,15....

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....net profit would come to Rs. 34,193 instead of Rs. 21,600 and according to the assessee's own showing there was concealment of Rs. 12,593. It was also found that the assessee had not accounted for the purchases made from the aforesaid two parties and there were numerous discrepancies in the account books. The IAC, therefore, found that the case was fully covered by the substantive provisions co....

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....llate Assistant Commissioner of Income-tax that the assessee had confessed the concealment of income for Rs. 12,593 ? 2. Whether the Appellate Tribunal was right in law in imposing penalty upon the assessee under section 271(1)(c) of the Act? " It was submitted before us on behalf of the assessee by Dr. K.B. Bhatnagar that purely because a certain addition had been made on account of extra p....

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....ment because it loses sight of the fact that the Explanation to s. 271(1)(c) is attracted to the case. The difference between the income returned by the assessee and the income finally assessed was more than 20 per cent. and the Explanation to s. 271(1)(c) was clearly attracted. It shall be deemed that the assessee concealed the particulars of his income and furnished inaccurate particulars of suc....