Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal

241 ITR 124High Court2000#1282 most cited

What is Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal authority for?

The initial burden to prove concealment of income or furnishing inaccurate particulars under Section 271(1)(c) lies with the Revenue. Penalty cannot be levied if the assessee offers a reasonable and bonafide explanation for the undisclosed income, even if it is offered after a survey or in response to a notice under Section 148.

89

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2025.

Also referred to as

CIT v. Suresh Chandra Mittal · 241 ITR 124 · Section 271(1)(c) penalty · concealment of income · inaccurate particulars · burden of proof · bonafide explanation · reasonable cause · disclosure during survey · income offered under Section 139(1) · notice under Section 148

Sections most often in play

Section 271(1)(c)Section 132Section 153ASection 139(1)Section 142(1)Section 234BSection 69Section 143(3)

Issues it is cited on

section 90(3)section 65(b)section 270a(2)(a)section 194ldsection 9(i)(vii)section 9(i)section 194lsection 65b(4)section 163section 276section 270a(2)section 270a(6)

Judgments citing Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal

BRIJ GOPAL CONSTRUCTION COMPANY (P) LTD.,NEW DELHI vs. ACIT, CENTRAL CIRCLE-3, DELHI

In the result, assessee’s appeal is allowed

ITA 4800/DEL/2025[2017-18]Status: DisposedITAT Delhi28 Nov 2025AY 2017-18

Bench: Shri M Balaganesh & Ms. Madhumita Royassessment Year: 2017-18

Section 1Section 143Section 143(3)Section 270ASection 270A(2)(a)

…(Del) CIT v. Arctic Investment (P) Ltd. vi) 145 Taxman 530 (Del) CIT v. Globe Sales Corporation vii) 219 ITR 267 (Del) CIT v. J. K. Synthetics Limited viii) 160 ITR 94 (AP) (FB) CIT V. H. Abdul Bakshi ix) 219 CTR 447 (Kar) Bhadra Advancing (P) Ltd. v. ACIT x) 241 ITR 124 (MP) affirmed in 251 ITR 9 (SC) CIT v. Suresh Chandra Mittal "It is well settled that under section 271(1)(e) the initial burden lies on the Revenue to establish that the assessee had concealed the income or had furnished inaccurate particulars of such income. The burden shifts to the assessee only if he fails to offer any explanation for the und…

VENKATESH RAGHAV RAO HEBBANI,NEW DELHI vs. INCOME TAX OFFICER WARD 34(5), NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 474/DEL/2025[2015-16]Status: DisposedITAT Delhi26 Sept 2025AY 2015-16

Bench: SHRI SATBEER SINGH GODARA (Judicial Member), SHRI S. RIFAUR RAHMAN (Accountant Member)

For Appellant: Shri Shubham Jain, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 139(1)Section 147Section 148Section 148ASection 194ISection 271(1)(C)Section 271(1)(c)

…3. Bonafide Explanation Ignored: The learned CIT(A) overlooked the reasonable cause provided by the appellant, including financial hardships and delays due to valid reasons, which were supported by the principles established in CIT vs. Suresh Chandra Mittal (241 ITR 124) and CIT vs. Reliance Petroproducts (322 ITR 158). 4. Erroneous Confirmation of Penalty: The CIT(A) erred in confirming the penalty without appreciating that:  TDS was already deducted by the employer.  Relevant taxes on the immovable property transaction were duly paid under Section 194IA.  No deliberate intention of concealment existed on th…

ASSISTANT COMMISSIONER OF INCOME TA , JAIPUR vs. SHRI NATH CORPORATION, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 267/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

…\n11.\n13.\n14.\nCopy of order of The Hon'ble Rajasthan High Court in the case of\nCommissioner of Income Tax v. Kanhaiyalal, (2008) 299 ITR 19 (Raj)\nCopy of order of the Hon'ble Supreme Court in the case of\nCommissioner of Income Tax Vs Suresh Chand Mittal 241 ITR 124\nCopy of order of the Hon'ble Delhi High Court in the case of\nCommissioner of Income Tax Vs. M/s SAS Pharmaceuticals Pvt. Ltd.\n335 19 ITR 259 (Delhi)\n186-\n192\n193-\n194\n195-\n200\n10.\nWe have carefully heard both parties and examined the material available on record. At the outset, we note that the core controversy relates to whether discl…

ASSISTANT COMMISSIONER OF INCOME TAX, JAIPUR vs. JITENDRA KUMAR AGARWAL, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 197/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Hemang Gargieya, Adv. &For Respondent: Shri Ajey Malik, CIT (through V.C.) a
Section 133ASection 271(1)(c)

…. Copy of order of The Hon'ble Rajasthan High Court in the case of 186- Commissioner of Income Tax v. Kanhaiyalal, (2008) 299 ITR 19 (Raj) 192 13. Copy of order of the Hon'ble Supreme Court in the case of 193- Commissioner of Income Tax Vs Suresh Chand Mittal 241 ITR 124 194 14. Copy of order of the Hon'ble Delhi High Court in the case of 195- Commissioner of Income Tax Vs. M/s SAS Pharmaceuticals Pvt. Ltd. 200 335 19 ITR 259 (Delhi) 10. We have carefully heard both parties and examined the material available on record. At the outset, we note that the core controversy relates to whether disclosure of additional…

ASSISTANT COMMISSIONER OF INCOME-TAX, JAIPUR vs. ROYAL JEWELLERS, JAIPUR

In the result, the appeals filed by the Revenue are dismissed

ITA 196/JPR/2024[2015-16]Status: DisposedITAT Jaipur24 Sept 2025AY 2015-16
For Appellant: Shri Hemang Gargieya, Adv. &
Section 133ASection 271(1)(c)

…\n11.\n13.\n14.\nCopy of order of The Hon'ble Rajasthan High Court in the case of\nCommissioner of Income Tax v. Kanhaiyalal, (2008) 299 ITR 19 (Raj)\nCopy of order of the Hon'ble Supreme Court in the case of\nCommissioner of Income Tax Vs Suresh Chand Mittal 241 ITR 124\nCopy of order of the Hon'ble Delhi High Court in the case of\nCommissioner of Income Tax Vs. M/s SAS Pharmaceuticals Pvt. Ltd.\n335 19 ITR 259 (Delhi)\n186-\n192\n193-\n194\n195-\n200\n10.\nWe have carefully heard both parties and examined the material\navailable on record. At the outset, we note that the core controversy relates\nto whether dis…

SOM NATH VIRMANI AND SONS HUF,HARYANA vs. INCOME TAX OFFICER WARD-4(1), GURGAON, HARYANA

In the result, the appeal of the Assessee is allowed

ITA 5081/DEL/2024[2015-16]Status: DisposedITAT Delhi20 May 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri M. Balaganeshm/S. Som Nath Virmani & Vs. Income Tax Officer, Sons Huf, Ward-5(1), Flat No. 303, Soverign 1, Gurgaon Vatika City, Sector-49, Sohna Road, Gurgaon-122001 Haryana (Appellant) (Respondent) Pan: Aanhs1927F Assessee By : Dr. Rakesh Gupta, Adv Shri Somit Aggarwal, Adv Revenue By: Shri Manish Gupta, Sr. Dr Date Of Hearing 20/05/2025 Date Of Pronouncement 20/05/2025

For Appellant: Dr. Rakesh Gupta, AdvFor Respondent: Shri Manish Gupta, Sr. DR
Section 144BSection 147Section 148Section 271(1)Section 271(1)(c)

…, the penalty levied by the AO, u/s 271(1)(c) is not justified and is liable to be deleted. In support of his contention, he has relied upon the following decisions:- (1) CIT vs. Pushpendra Surana, (2014) 264 CTR 204 (Raj). (ii) CIT vs. Suresh Chandra Mittal, 241 ITR 124 (MP) (iii) CIT vs. Gujarat State Electricity Corporation Ltd., 144 taxmann.com 165. M/s. Som Nath Virmani and Sons HUF 8. On the other hand, the Ld. Departmental Representative had relied upon the orders of the authorities below and submitted that the assessee did not file the return of income u/s 139(1) of the Income-tax Act, 1961, but the retu…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7760/DEL/2017[2012-13]Status: DisposedITAT Delhi12 Jun 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7759/DEL/2017[2011-12]Status: DisposedITAT Delhi12 Jun 2024AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7758/DEL/2017[2010-11]Status: DisposedITAT Delhi12 Jun 2024AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7757/DEL/2017[2009-10]Status: DisposedITAT Delhi12 Jun 2024AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 7756/DEL/2017[2008-09]Status: DisposedITAT Delhi12 Jun 2024AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6769/DEL/2017[2007-08]Status: DisposedITAT Delhi12 Jun 2024AY 2007-08

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6767/DEL/2017[2006-07]Status: DisposedITAT Delhi12 Jun 2024AY 2006-07

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6744/DEL/2017[2007-08]Status: DisposedITAT Delhi12 Jun 2024AY 2007-08

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, CENTRAL CIRCLE- 30, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 6743/DEL/2017[2006-07]Status: DisposedITAT Delhi12 Jun 2024AY 2006-07

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3627/DEL/2016[2012-13]Status: DisposedITAT Delhi12 Jun 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3626/DEL/2016[2011-12]Status: DisposedITAT Delhi12 Jun 2024AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3625/DEL/2016[2010-11]Status: DisposedITAT Delhi12 Jun 2024AY 2010-11

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3624/DEL/2016[2009-10]Status: DisposedITAT Delhi12 Jun 2024AY 2009-10

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

RAJINDER KUMAR,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeals filed by the assessee on quantum for AY 2006-

ITA 3623/DEL/2016[2008-09]Status: DisposedITAT Delhi12 Jun 2024AY 2008-09

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri V. Sridharan, Sr. AdvFor Respondent: Shri P. N. Barnwal, CIT DR
Section 132Section 143(2)Section 153A

…001) 251 ITR 9] (Page 772-773 of case law compendium, Volume 3.2) the Hon'ble Supreme Court upheld the view taken by the Hon'ble Madhya Pradesh High Court. The Hon'ble High Court of Madhya Pradesh in Commissioner of Income Tax v. Suresh Chandra Mittal [(2000) 241 ITR 124] (Page 774- 776 of case law compendium, Volume 3.2) has held that once the revised assessment was filed by the Assessee and regularised by the Revenue and once the Assessing Authority had failed to take any objection in the matter, the declaration of income made by the assessee in his revised returns and his explanation that he had done so to buy…

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