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19. The contents of the Tax Audit Report suggest that there is no
question of the assessee concealing its income. There is also no question
of the assessee furnishing any inaccurate particulars. It appears to us
that all that has happened in the present case is that through a bonafide
and inadvertent error, the assessee while submitting its return, failed to
Mahesh Kumar Agrawal
add the provision for gratuity to its total income. This can only be
described as a human error which we are all prone to make. The caliber
and expertise of the assessee has little or nothing to do with the
inadvertent error. That the assessee should have been careful cannot be
doubted, but the absence of due care, in a case such as the present, does
not mean that the assessee is guilty of either furnishing inaccurate
particulars or attempting to conceal its income.