1975 (9) TMI 35
X X X X Extracts X X X X
X X X X Extracts X X X X
....iced on account of the Income-tax Officer examining the bank manager behind the assessee's back ? (3) Whether the imposition of penalty under section 271(1)(c) of the Act is at all warranted ?" Assessee is a registered firm and carries on business in brooms and jungle products. The year of assessment with which we are concerned is 1962-63. The Income-tax Officer determined the income at Rs. 76,657 which included a sum of Rs. 10,000 said to be credit received by the firm from two persons and an addition of Rs. 41,075 as income from concealed sources. Assessee's appeals for omission of the additions failed before the Appellate Assistant Commissioner. The Appellate Tribunal accepted the assessee's contention in regard to Rs. 10,000 and dir....
X X X X Extracts X X X X
X X X X Extracts X X X X
....point relevant to its explanation. The Income-tax Officer rejected the explanation of the assessee and added the amount as income from a concealed source. Consequently, proceedings were taken under section 271(1)(c) of the Act and penalty was also levied. Both the appeals before the Appellate Assistant Commissioner as also the Tribunal failed. Before the Appellate Tribunal while the claim was reduced by deduction of Rs. 10,000 as already indicated, the rest of the addition was sustained and imposition of penalty was not interfered with. The Appellate Tribunal drew adverse inference against the assessee by saying that the evidence placed before it was not well-founded because of the fact that no material question was put by the Income-tax ....