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1973 (4) TMI 35 - RAJASTHAN HIGH COURT
Failure to maintain proper method of accounting and quantitative details - assessments were made on the basis of estimate - " Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that the assessee was not guilty of fraud or gross or wilful neglect within the meaning of the Explanation to section 271(1)(c) of the Act ? " - In the result, in none of the six cases any question of law arises be cause whether the presumption raised by the Explanation to section 271(1)(c) has been rebutted or not is essentially a question of fact and we decline to direct the Tribunal to refer any, question to us