TMI Blog2003 (12) TMI 12X X X X Extracts X X X X X X X X Extracts X X X X ..... n on the assessee to show that the additional income that had not been disclosed was not due to fraud or neglect - assessee offered no explanation at all except to assert that he disclosed the income only to buy peace with the Department and what was disclosed, in fact, was additional income. The reason for not having disclosed the income earlier was not stated. In these circumstances, the Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r 22,1985, at which time cash, jewellery and certain documents were seized. Thereafter, a revised return was filed by the assessee for this assessment year, which return was accepted and assessment made on the basis of that return. The assessee in response to the notice seeking to impose penalty, took the stand that there was no concealment and it was only for the purpose of buying peace with th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Explanation casts a burden on the assessee to show that the additional income that had not been disclosed was not due to fraud or neglect. In this case, the assessee offered no explanation at all except to assert that he disclosed the income only to buy peace with the Department and what was disclosed, in fact, was additional income. The reason for not having disclosed the income earlier was no ..... X X X X Extracts X X X X X X X X Extracts X X X X
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