COMMISSIONER OF INCOME TAX Vs. G R RAJENDRAN

JUDGEMENT

(1.) THE question referred to us at the instance of the Revenue is :

(2.) THE Assessing Officer levied penalty on the ground that the assessees had concealed their income inasmuch as a raid carried out in the assessees' premises had resulted in substantial quantum of jewellery being found, some of which had not been declared by the assessees and the members of their family. THE assessees had offered an explanation for that excess quantity of jewellery. That explanation however was not considered by the Assessing Officer. He proceeded to levy the penalty by observing that the period of limitation was running out and therefore he has to make a final order.