V.L. Dutt vs Commissioner Of Income-Tax on 24 December, 1975
3. Some argument was sought to be advanced that the Tribunal had not decided on the question of mens rea. On this aspect, reliance was placed on certain observations in the case of V.L. Dutt v. CIT .. The Tribunal seems to have proceeded on the basis that even if the mental element was necessary whether, in a particular case, sufficient cause was made out or not is a question of fact and the Tribunal has taken into consideration all the relevant facts, as have been mentioned hereinbefore, and was right in its conclusion. In these circumstances, in our opinion, it cannot be said that the Tribunal committed any error of law or erred in arriving at its conclusion which it did.