CIT KERALA Vs. E AHAMED

JUDGEMENT

(1.) This Tax Referred Case has come up before the Full Bench on an order of Reference by a Division Bench dated 28th November, 1972. The reference was made because of the conflict between the decisions in ITR No. 38 of 1970 and ITR. No. 71/1968.

(2.) The question is:

(3.) By the amendments introduced by the Finance Act, 1964, the word "deliberately" has been omitted from Clause (c) of Sub-s.(1) of S.271 and an explanation was added which is in these terms: