1993 (1) TMI 21

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..... reme Court from the judgment in Income-tax Reference No. 287 of 1982 (CIT v. Bharath Sea Foods [1992] 195 ITR 60 (Ker)). At the instance of the Revenue, the following question came up for consideration in Income-tax Reference No. 287 of 1982 (see [1992] 195 ITR 60, 61) : "Whether, on the facts and in the circumstances of the case and in view of the application of the Explanation to section 271(1 .....

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..... irected itself in law in reducing the penalty imposed by the Inspecting Assistant Commissioner from the amount of Rs. 1,05,000 to Rs. 47,000. The Appellate Tribunal had relied on materials which were not relied on by both sides. It was not the case of the assessee nor that of the Department that the opening balance in the ledger did not reflect the true state of affairs. Concealment was found agai .....

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