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EXPLANATION 2 TO SECTION 271(1)

Income Tax - Penalties - Circumstances, Procedures and Relief - 03 - Additions are sometimes made by the assessing Officer for purely technical reasons, e.g., application of a presumptive rate of gross profit or of yield, or on account of estimated d .....

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essments, when called upon to explain certain deposits, etc., the assessee urges at times that such deposits, etc., have come out of the income represented by the aforesaid additions made earlier. Despite this virtual confession of concealment on the .....

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espect of the year in which the deposit was made as there was no concealment in that year, the deposit having been explained as out of an earlier year s income. Explanation 2 to section 271 provides that in such cases, the assessee would become liabl .....

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y assessment year (i.e.., current year) is claimed by any person to be amount which had been added in computing the income or deducted in computing the loss in the assessment of such person for any earlier assessment year (i.e., earlier year) In resp .....

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eceipt, deposit or outgoing or value of such investment shall be treated as the income of the assessee, particulars of which had been concealed or inaccurate particulars of which had been furnished for the earlier year. The following points should al .....

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