COMMISSIONER OF INCOME Vs. DHARAM PAL SINGH

JUDGEMENT

(1.) By this application, the Revenue is asking this court to direct the Tribunal to state the following question :

(2.) We have seen the order of the Tribunal. Out of the ten donations put forward by the assessee, five are accepted and five are rejected. The Tribunal has said that merely because the evidence in respect of five donations was not accepted or believed, it does not follow that there was gross fraud or wilful neglect, even though this is a case of penalty proceedings under section 271(1)(c) of the Income-tax Act. We do not think that a question of law arises from the order of the Tribunal as it has recorded a finding that there was no proof of wilful or fraudulent concealment.

(3.) The application is accordingly rejected.