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1972 (12) TMI 6 - HC - Income Tax
Reassessment proceedings - Surrender by the assessee of some debts in reassessment proceedings - whether such surrender is enough to initiate penalty proceedings - held that there may be hundred reasons for the assessee to surrender the amount irrespective of the fact whether it was his income or not and it was incumbent for the Income-tax Officer to find on evidence that the amount surrendered represented the income of the assessee. As a result of the above discussion, we are clearly of the view that, on the facts and circumstances of this case, the order imposing penalty was not justified