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TMI Blog2002 (4) TMI 884X X X X Extracts X X X X X X X X Extracts X X X X ..... appeals have been filed by the revenue against the orders of CIT(A) for assessment years 1981-82 and 1982-83. For the assessment year 1981-82, the appellant agitated on the ground that the ld. CIT(A) has erred in reducing the penalty of Rs. 1,04,550 imposed under section 271(1)(c) to Rs. 19,810 without adequate justification. Similarly, for assessment year 1982-83 the ld. CIT(A) has erred in reduc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mpleted on 31-3-1984 in which the total income was determined as under :- Income as returned above : Rs. 1,12,300 Disallowance of loss-Silver refinery : Rs. 15,000 Lumpsum addition as considered by CIT but not included by the assessee : Rs. 5,000 Unexplained investment in the factory building : Rs. 14,000 Rs. 1,46,300 The income as assessed was confirmed by the C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e since the return of income has been filed after the search & seizure operation and including the major portion of the income assessed subsequently that there can be no substantive concealment on the part of the assessee. Therefore, the ld. CIT(A) came to the conclusion that there is only concealment of income amounting to Rs. 30,020 (Rs. 1,42,320 minus Rs. 1,12,300). Similarly for assessment ye ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s return of income : Rs. 3,024 (iii) Unexplained acquisition of silver ornaments : Rs. 4,570 (iv) Unexplained investment in value of mixed metal : Rs. 9,150 The above additions were confirmed by the CIT(A), Jodhpur. The Assessing Officer held that the assessee had furnished inaccurate particulars of its income to the extent of Rs. 1,03,250 being the difference between the income assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X
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