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TMI Blog1980 (11) TMI 73X X X X Extracts X X X X X X X X Extracts X X X X ..... of the WT Act. The assessee is a partner in the firm of M/s. Narbheram Pranshankar Co. According to the WTO, the assessee While filing the original return had not disclosed his share in the reserve fund in the account of the said firm in which he was a partner. The assessee, however, filed a revised return disclosing a sum of Rs. 24,000 being his share in the reserve fund. The WTO brought to tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... epresentative submitted that the moment this omission was brought to the notice of the assessee, the assessee promptly filed the revised return which was accepted by the WTO. The revenue, on the other hand, contended that the assessee had omitted to disclose the said amount in the return of the net wealth and, therefore, the omission to disclose the correct amount in the return of net wealth filed ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of about Rs. 250. Therefore, when the additional tax liability for disclosing the amount was marginal, no assessee would ordinarily attempt a non-disclosure of the amount when the penal consequences would be extremely onerous. Therefore, having regard to the balance of probability and having regard to the normal conduct, we are of the opinion that the omission to disclose the impugned amount was ..... X X X X Extracts X X X X X X X X Extracts X X X X
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