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TMI Blog1980 (4) TMI 198X X X X Extracts X X X X X X X X Extracts X X X X ..... was required to pay advance tax of Rs. 27,682 under s. 210 of the Act. The assessee filed an estimate on 10th Sept., 1971 estimating the tax payable under s. 212 of the Act at only Rs. 1,926 on the estimated income Rs. 56,820. The assessee later filed the IT return on 1st Aug., 1972 showing the total income at Rs. 70,890 and the tax payable under s. 140A at Rs. 12,900. The ITO initiated penal acti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 63,500 76,674 . 6,680 5,780 Total Income 56,820 70,890 The assessee submitted that at the time of filing the estimate, the assessee believed on the materials before him that this income would not exceed Rs. 56,820 and hence the assessee had reasonable cause. The AAC observed that the salary income was understated by Rs. 4,500 and the prop ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for advance-tax purpose. The counsel submitted that the loss in property shown by the assessee was consistent with the property income returned by him for the earlier year and this difference in the income was one of the reasons for the advance-tax estimate being lower than the income returned by him. Regarding the salary income, the assessee's counsel submitted that the assessee received Rs. 57, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by him for the earlier years in the IT return. The property income declared by him in the IT return was subsequent to the ITO's assessment for the preceding year 1971-72, which the assessee decided to follow at the time of filing the return and hence it cannot be said that as on the date of filing the advance-tax estimate, he had deliberately understated his income. Regarding the salary income als ..... X X X X Extracts X X X X X X X X Extracts X X X X
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