- (1.) WE heard counsel for the Revenue.
(2.) THE assessee filed its return on July 30, 1980, for the assessment year 1980 -81 declaring an income of Rs. 21,97,794. The income of the assessee, however, was computed at Rs. 24,02,551 by the Assessing Officer vide assessment order dated March 15, 1983. On the basis of the addition made by the Assessing Officer, he initiated proceedings for penalty and imposed a penalty of Rs. 7,10,155 under Section 271(T)(c) of the Income -tax Act, 1961.
(3.) IN appeal by the assessee before the Commissioner of Income -tax (Appeals), the modification in the order concerning addition in two categories was made. However, the Commissioner of Income -tax held that the part of penalty was leviable.;