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TMI Blog1998 (1) TMI 7X X X X Extracts X X X X X X X X Extracts X X X X ..... ing that as the difference between the income assessed and the income returned was more than 20 per cent., therefore, the said Explanation became applicable and the ITO was justified in imposing penalty - Civil Appeals Nos 1515, 1516 and 1517 of 1985. - - - Dated:- 22-1-1998 - B. N. KIRPAL AND S. P. KURDUKAR JJ. For the Appellant : Ms. Janaki Ramachandran, Advocate For the Respondent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TR 14 (SC) : TC 50R.474; CIT vs. K.R. Sadayappan (1990) 86 CTR (SC) 120: (1990) 185 ITR 49 (SC) : TC 50R.795 and Addl. CIT vs. Jeevan Lal Sah (1994) 117 CTR (SC) 130: (1994) 205 ITR 244 (SC) : TC 50R.973. In these decisions it has been clearly stated that with the incorporation of the Expln. to s. 271, the view which had been taken earlier in CIT vs. Anwar Ali (1970) 76 ITR 696(SC) : TC 50R.276, n ..... X X X X Extracts X X X X X X X X Extracts X X X X
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