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In the result, the appeal is allowed and the order passed by the learned
Bench: THE HON'BLE THE CHIEF JUSTICE T.S SIVAGNANAM,HON'BLE JUSTICE CHAITALI CHATTERJEE (DAS)
13. The expression “the assessee offers no explanation” occurring in Section 68 of the Act was explained by Hon’ble Supreme Court in P. Mohanakala to mean where the assessee offers no proper reasonable and acceptable explanation as regards the sums found credited in the books maintained by the assessee and that the opinion of the assessing officer