(1.) THE following two questions are referred for our decision :
(2.) FOR the assessment year, among other items, the assessee claimed that he has borrowed a sum of Rs. 29,000 from one Nanjappa Devar. This claim of the assessee was not accepted by the Income-tax Officer and consequently that amount was included in the assessee's income. Since he has not accepted that the sum of Rs. 29,000 was borrowed, penalty proceedings were initiated under section 271(1)(c) of the Income-tax Act and penalty also was levied by the Inspecting Assistant Commissioner.