2002 (10) TMI 71

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..... on offered by the person being found to be false or not being one which the person offering the explanation is able to substantiate. The consideration of the explanation offered is, therefore, a duty cast upon the officer imposing penalty. In the absence of such consideration and the finding that the explanation is false or that the assessee had failed to substantiate the explanation offered, the .....

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..... resulted in substantial quantum of jewellery being found, some of which had not been declared by the assessees and the members of their family. The assessees had offered an explanation for that excess quantity of jewellery. That explanation however was not considered by the Assessing Officer. He proceeded to levy the penalty by observing that the period of limitation was running out and therefore .....

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