TMI Blog2013 (7) TMI 734X X X X Extracts X X X X X X X X Extracts X X X X ..... e in its books of account. The said amount was also held to be available with the petitioner relating to the assessment year 1984-85 - Following decision of The Commissioner of Income Tax, Patiala Vs. M/s Ghunna Ram & Sons [2010 (11) TMI 854 - PUNJAB & HARYANA HIGH COURT] - Decided in favour of Revenue. - CWP No.163 of 1999 - - - Dated:- 9-1-2012 - M. M. Kumar And Ajay Kumar Mittal,JJ. Fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sty scheme for the assessment year 1976-77 and 1977-78 and had prayed for deletion of addition on account of unaccounted cash and for credit of this amount. The penalty proceedings under section 271 (1) (c ) of the Act were initiated for concealment of income. 3. The petitioner filed a petition under Section 264 of the Act before respondent No.1 with the averments that it had surrendered an amou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... earned counsel for the petitioner, learned counsel for the revenue supported the order passed by respondent No.1. 6. After giving thoughtful consideration to the respective submissions, we are of the view that respondent No.1 was not justified in rejecting the prayer. It was not disputed that in the proceedings relating to assessment year 1982-83 wherein the assessee had claimed that the amount ..... X X X X Extracts X X X X X X X X Extracts X X X X
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