1991 (1) TMI 76

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..... r opinion : "Whether, on the facts and in the circumstances of the case, there was any material to support the finding that the assessee believed that he was under no statutory obligation to file a return and whether, under all the facts and circumstances of the case, the explanation of the assessee constituted, in law, 'reasonable cause' ? " The assessee is an individual. The assessment years .....

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..... tion 271 as well as under clause (a) of sub-section (1) of section 271 against the assessee. It appears that the proceedings under section 271(1)(c) were concluded earlier. It was found in those proceedings that the assessee had not concealed any income nor had he furnished any inaccurate particulars. Of course, it appears that the decision in those proceedings turned on the question of burden of .....

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