(1.) This is a reference at the instance of 'the Commissioner of Income Tax under S.256(1) of the Income Tax Act; and the question of law referred is:
(2.) The Explanation added to S.271(1)(c) is as follows:
(3.) We think that the explanation given by the assessee read in the light of the facts and circumstances of the case was sufficient to warrant the conclusion that the assessee was not guilty of fraud or gross or wilful negligence in furnishing the return.