KALIPADA SAHA,HOOGHLY vs. ITO, WARD-24(3),HOOGHLY. , HOOGHLY

In the result, all the four appeals of the assessee are dismissed

Bench: Shri Rajpal Yadav & Shri Rakesh Mishra

penalty u/s. 271(1)(c) is the civil liability for which wilful concealment is not an essential ingredient for attracting the provisions, unlike in the proceeding u/s. 276C of the Act. Had the notice u/s. 148 not been issued in all these four years, such income would not have been offered to tax. The assessee failed to give any justification