suppression of material facts. But none of appellate authority have held that the material facts relating to computation of income have been suppressed ... addition/disallowance and there is no finding that the assessee had suppressed material relating to these disallowances. Therefore, it cannot be said that the assessee
company and entered into agreement(s) of sale by suppressing material facts concerning the transaction. Since money advanced is not recoverable, the entire amount
that in absence of any overt act, which
indicates conscious and material suppression, invocation of
Explanation 7 in a blanket manner could not only
basis for all the assessment
years though there was no seized material indicating
suppression of receipts for these assessment years ... estimate basis for all the assessment years.
There was no material indicating suppression of receipts.
9. We find that the Tribunal has not committed
explanation remains unsubstantiated. There
is no finding that the assessee has suppressed material
relating to disallowance. Therefore, it cannot be said that the
assessee ... guilty of suppressing material facts relating to its
income. There is also no finding that full material facts have
not been disclosed by the assessee
queries raised, the Assessing Officer could draw an adverse inference regarding suppression of material facts. In such circumstances the Assessing Officer could take into account ... evasive answers, the ITO could draw an adverse inference regarding the suppression of material facts. The ITO could also take into account what might
cash deposited in the bank account thereby
suppressing material facts in understanding the nature of cash inflow and
its destination. Entire transaction of deposits
assumption that the assessee was guilty
of non-disclosure or suppression of material facts which
ought to have been primarily revealed to the Settlement
Commission ... disclose material or
facts which are germane and relevant, or suppressing facts
and materials which are germane and relevant or holding out a
falsehood which
clear cut cases where inflated deduction has been
claimed by suppressing material facts and income escaping assessment is of
the order of over ... truly all material facts
necessary for his assessment. The duty of the assessee does not extend beyond the
disclosure of all material facts necessary
case where
the assessee had attempted to mislead or suppress material facts and
which may have warranted the case of the assessee being placed ... authorities below have held that the appellant was guilty of
suppression. We would thus be inclined to allow the instant appeal
and answer the question
