COMMISSIONER OF INCOME TAX Vs. N. NANDAKUMAR

JUDGEMENT

(1.) The questions of law raised in this appeal by the appellant are the following :

(2.) Whether, on the facts and in the circumstances of the case and in the absence of a finding of bona fide in the absence of findings (or consideration) contemplated under Expln. 1(B) to Section 271(1)(c), Tribunal is justified in relying on the same and in reaching the conclusion

(3.) Whether, on the facts and in the circumstances of the case and when the statute contemplates a finding of 'bona fide' (in discharge of onus) on the assessee, does the finding that 'there is nothing to show that the assessee's claim of receipt of tin sheets on loan from the sister-concern is not bona fide', 'merely because there is no entries in the books it would not be correct to say that the explanation was not bona fide' would amount to finding of bona fide