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1989 (4) TMI 64

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..... ether the limitation of eight years contained in section 153(1)(b) of the Income-tax Act, 1961 (for short "the Act"), would be applicable. The case relates to the assessment year 1972-73. On September 26, 1974, the premises of the assessee were searched and documents, registers and account books were taken into possession. The deduction of salary paid to its workers as shown in the attendance/ w .....

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..... rnish any explanation. There were certain other matters also which needed probe as it was apparent to the Income-tax Officer that the assessee had concealed its true income and had understated its income in the return filed under section 139(4) of the Act. Finally, on September 16, 1976, the Income-tax Officer framed the assessment after disallowing certain cash credits and the expenses claimed on .....

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..... report received from Nasik that the wages register was forged and there was concealment of income and section 271(1)(c) of the Act was applicable and the extended limit of eight years contained in section 153(1)(b) of the Act applied and on the date the Income-tax Officer framed the assessment, it was within the limitation of eight years. On further appeal by the assessee before the Tribunal, th .....

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..... of limitation. This was an endeavour to make false claim of deduction to defraud the Revenue. Not only this, the material was brought to the notice of the assessee by four letters written within limitation. This clearly shows that there was application of mind by the Income-tax Officer on the point that the assessee had concealed his income and the evidence which proved that was brought to its no .....

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