TMI Blog2000 (12) TMI 79X X X X Extracts X X X X X X X X Extracts X X X X ..... was wholly unwarranted as there had been no fraud and wilful neglect and the assessee had, only with a view to co-operate wit t e Department, agreed to the addition of the sum of Rs. 24,000 in the assessment of his income for the assessment year 1974-75, The assessing authorities had no material, apart from the fact that the assessee had agreed to the addition of that sum to his income for the pu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xt against any person and should not be lightly recorded in the absence of proper evidence in support of that finding. The court further observed that the fact that the Explanation to section 271(1)(c) of the Act required the assessee to show that there was no fraud or wilful neglect does not any way enable the Revenue to contend that there is a presumption of fraud or neglect without adducing any ..... X X X X Extracts X X X X X X X X Extracts X X X X
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