COMMISSIONER OF INCOME TAX Vs. BHARATH SEA FOODS

JUDGEMENT

(1.) INCOME-tax Reference No. 287 of 1982 is at the instance of the Revenue whereas INCOME-tax Reference No. 288 of 1982 is at the instance of the assessee. The question referred to this court for opinion at the instance of the Revenue reads :

(2.) THE question formulated at the instance of the assessee reads :

(3.) AGGRIEVED by this order, the assessee filed an appeal before the Appellate Tribunal which, while concurring with the finding of the Inspecting Assistant Commissioner that there was concealment, interfered with that order and reduced the penalty entering a finding that the con- cealment of the particulars of income can be stated to be only in respect of a sum of Rs. 47,000. How the Tribunal arrived at this figure, it is relevant to consider at this stage. We shall, in this connection, refer to the discussion discernible from the order of the Tribunal. It reads :