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TMI Blog1976 (11) TMI 56X X X X Extracts X X X X X X X X Extracts X X X X ..... llowing question : " Whether, on the facts and in the circumstances of the case, the Explanation to section 271(1)(c) of the Income-tax Act, 1961, inserted by the Finance Act, 1964, with effect from April 1, 1964, applies to the assessment years 1958-59 to 1962-63, on the ground that the returns of income were filed after April 1, 1964 ? " Sri R. C. Sharma, learned counsel for the respondent- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ply to the objection raised by Sri Sharma, the learned standing counsel appearing for the revenue submitted that under the Explanation to section 271 inserted by the Finance Act, 1964, when the total income returned by a person is less than 80 per cent. of the total income as assessed, the burden is on such person to prove that the failure to return the correct income did not arise from any fraud ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... idow who was not acquainted with the business of the assessee ; it is further to be borne in mind that the widow of the assessee volunteered the information in regard to the sales tax assessments on the basis of which the Income-tax Officer made the assessments in this case. It is further seen that the Income-tax Officer simply adopted the estimate made by the Sales Tax Officer in estimating the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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