COMMISSIONER OF INCOME TAX Vs. MITTAL K C

JUDGEMENT

(1.) IN pursuance of the directions of this court under Section 256(2) of the INcome-tax Act, 1961, the INcome-tax Appellate Tribunal (Delhi Bench 'D.', Delhi), has referred the following questions for the opinion of this court :

(2.) WE have heard Sri Shekhar Srivastava, learned counsel for the Revenue, and Sri Sakeel Ahmad, learned counsel for the assessee.

(3.) ADMITTEDLY, in this case, the income returned by the assessee was less than 80 per cent. of the income assessed. The Explanation to Section 271(1)(c) of the Act reads as below ;