Dipak Kumar Sen, J. - (1.) In this application under Section 261 of the Income-tax Act, 1961, the petitioner contends that substantial questions of law arise from the judgment in the above reference from which an appeal is sought to be preferred to the Supreme Court by the assessee.
(2.) Relying on a circular issued by the Central Board of Revenue No. 27(44-IT/52) dated 6th October, 1952, which was in force at the relevant time, the assessee credited interest receivable from his debtors in a suspense account instead of disclosing it in its return based on accounts kept on mercantile basis.
(3.) The substantial question of general importance which arises is that if there are two views on a particular issue and if the assessee proceeds on the basis of one view, whether there is deliberate concealment so as to attract penalty under Section 271(1)(c) of the Act ?;