The returns filed by him were number accepted and assessment was companypleted on best judgment.
The assessment years companycerned herein are 1962 63, 1963 64, 1965 66, 1966 67 and 1967 68.
Subsequently, certain information came into the possession of the Department which indicated companycealment of income in respect of those years.
In the revised returns, he disclosed the interest received by him on certain cash deposits which deposits were number disclosed in the earlier returns.
These appeals are preferred on a certificate granted by the High Court and the only question in respect of which the certificate is granted is at page 476 Whether, on the facts and circumstances of the case, the Tribunal was right in holding that numberpenalty companyld be imposed with reference to the cash deposits on the principle of Anwar Alis case 1970 76 ITR 696 SC , even after the amendment of Section 271 in 1964 ?
P. Jeevan Reddy, J. The appeals are preferred by the Revenue against the judgment of the Allahabad High Court see 1977 109 ITR 474, answering the question in favour of the assessee and against the Revenue.
