1981 (1) TMI 107

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....sed by the ITO under s. 271(1)(c) of the IT Act. 2. The assessee had filed a return showing an income of Rs. 59,220 and the finally assessed income after reduction in appeal comes to Rs. 66,310. The ITO has found that the assessee has not shown notional income from residential portion of property. The income from such residential portion was taken at Rs. 5,394 which has been confirmed in appeal....

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....on was included in the wealth of B.N. Kanodia, HUF. It was, therefore, contended that the assessee believed that no part of the income belonged to the HUF named Sadiram Ganga pd. The AAC considered the facts and held that primary facts had not been concealed and the inclusion of income was due to the difference of opinion between the Department and the assessee. He, therefore, held that this was n....