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Issues Involved:
The judgment involves the assessment of undisclosed income and interest income, appeals before the Commissioner of Income-tax (Appeals) and the Income-tax Appellate Tribunal, imposition of penalty under section 271(1)(c) of the Income-tax Act, and the application for reference to the High Court. Assessment of Undisclosed Income and Interest Income: The assessee, not maintaining books of account, had additions made to his income for the assessment year 1981-82 based on seized materials during a search, leading to a conclusion of concealment of income. The Commissioner of Income-tax (Appeals) upheld the addition of Rs. 2 lakhs as undisclosed income but deleted the interest income of Rs. 1,11,000. The Tribunal dismissed the assessee's appeal against the undisclosed income addition, while the Revenue conceded that only Rs. 64,042 of the interest income was traceable to the assessee. Imposition of Penalty under Section 271(1)(c): Penalty proceedings were initiated against the assessee for concealment of income and interest income. The Assistant Commissioner imposed a penalty of Rs. 1,29,936 under section 271(1)(c) of the Income-tax Act. The assessee's appeals against the penalty imposition were unsuccessful before the Commissioner of Income-tax (Appeals) and the Tribunal. Application for Reference to High Court: The assessee filed an application under section 256(1) of the Income-tax Act to refer questions of law to the High Court regarding the Tribunal's decision on the penalty levy and concealment of income. The Tribunal dismissed the reference application, leading to the present action - Tax Case Petition No. 757 of 1997. Conclusion: The High Court reframed the questions of law and upheld the Tribunal's decision on the penalty levy and concealment of income. The Tribunal was deemed right in its findings based on the admitted facts and actions of the assessee and the Revenue. Consequently, the tax case petition was dismissed, affirming the Tribunal's decision.
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