Law:

Section:

Section 147 of the Income-tax Act, 1961 - Income escaping assessment - General - Assessment year 1981-82 - Whether no specific form for recording reasons under section 148 has been prescribed under Act or Rules made thereunder and if an assessee voluntarily files a return for which omission has been detected in assessment proceedings in subsequent assessment year and taking note of revised return, a notice under section 148 is issued, reasons would be sufficient - Held, yes - Whether where reassessment has become final between parties, unless and until reassessment is specifically challenged in appropriate proceedings, either by way of an appeal, revision or by way of writ petition under article 226 of Constitution, no advantage can be taken by assessee regarding invalidity of reassessment proceedings in collateral proceedings - Held, yes Section 271(1)(c) of the Income-tax Act, 1961 - Penalty - For concealment of income - Assessment year 1981-82 - Assessee did not disclose stock of Kinki rice and Ghuta rice in its closing stock while filing return for assessment year 1981-82 - When said omission was detected in course of assessment proceedings for subsequent assessment year 1982-83, assessee filed revised return declaring closing stock of Ghuta rice and Kinki rice and explained that it was under bona fide belief that it was not required to be disclosed - Assessing Officer levied penalty under section 271(1)(c) - Whether since explanation offered by assessee was bona fide and also stood substantiated specially when closing stock of Ghuta rice and Kinki rice though not disclosed in assessment year 1981-82 had been voluntarily disclosed in revised return filed and which stocks had been bona fidely disclosed by assessee in subsequent assessment year, i.e., 1982-83 penalty could not be levied - Held, yes Section 254 of the Income-tax Act, 1961 - Appellate Tribunal - Powers of - Assessment year 1981-82 - Whether Appellate Authority has power to permit party to raise additional ground which had not been raised in memorandum of appeal and further in penalty proceedings, fresh material can be considered which was not available at time of assessment or while passing…

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