1987 (1) TMI 120

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nbsp;                                   This appeal is directed against the imposition of penalty under s. 271(1)(c) of the IT Act, 1961. 2. The assessee is a registered firm carrying on business in foodgrains. In the course....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....22,000 as income of the assessee from undisclosed sources. This also led to the imposition of penalty under s. 271(1)(c), which was confirmed by the AAC. In the appeal before us, it was contended on behalf of the assessee that since the amount was surrendered on an assurance that no penalty will be imposed there was no jurisdiction for the imposition of penalty as held by the Allahabad High Cou....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tself. Secondly, the assessee has given an explanation that they were credits given to agriculturists who had given their products for sale and also given their names. The assessee had also offered to furnish further evidence if called upon. But, it is only because of the assurance that a penal action would not be taken that the assessee surrendered the amount for addition. The Expln. 1 to s. 271(....