- (1.) The matter here relates to the imposition of penalty, under Section 271(1)(a) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act').
(2.) The assessee is a private limited company carrying on the business of passenger transport. During the assessment years 1966-67 and 1968-69, the receipts disclosed by the assessee were as under :- 1966-67Rs. 11,88,666/- 1968-69Rs. 13,33,003/-
(3.) The Income Tax Officer found that the assessee had not accounted for all the passengers tax stamps purchased by it during the assessment years in question. The unaccounted for passengers tax stamps for 1966-67 being of the value of Rs. 33,819/- and for 1968-69 of Rs. 12,687/-. The explanation furnished by the assessee with regard to the discrepancy between the passenger tax tickets purchased and accounted for was not accepted by the Income Tax Officer and consequently a sum of Rs. 90,000/- was added to the receipts declared by the assessee for the year 1966-67 and Rs. 52,000/- for 1968-69. Penalty proceedings under Section 271(1)(a) of the Act were also initiated against the assessee.;