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2004 (1) TMI 13

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..... in the form of a pass book and another copy of the bank ledger. The pass book normally reflects whatever is in the ledger but, if in respect of two entries there is an error committed by the bank officials and the same is relied upon by the assessee and the latter's explanation is accepted, we do not think that any case is made out – revenue’s appeal rejected - - - - - Dated:- 12-1-2004 - Judge( .....

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..... ect. The assessee has rendered the explanation and paid the tax. The Commissioner of Income-tax (Appeals) has accepted the explanation that the assessee did not engage any accountant and was in the habit of filing his own return of income and the mistake occurred inadvertently. The explanation has been considered to be bona fide by the Tribunal also. Learned counsel for the Revenue has relied upon .....

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..... income have been disclosed by him, then, the amount added or disallowed in computing the total income of such person as a result thereof shall, for the purposes of clause (c) of this sub-section, be deemed to represent the income in respect of which particulars have been concealed." Thus, it is necessary that if a person has failed to offer an explanation or offers an explanation which is found .....

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