In the result, the assessee’s appeal is dismissed
Bench: Sh. Sanjay Arorai.T.A No.440/Asr/2017 Assessment Year:2011-12
u/s. 271(1)(c), also exhibiting as to how these are, thus, different from the assessment proceedings. A plausible explanation, thus, saves penalty. The requirement of substantiation, it may be appreciated, is toward establishing the truth of the explanation furnished. The burden to so explain is though on the assessee, failing which the assessee is deemed by law to have