JUDGMENT

Ashok Bhan, J. —

1. These appeals have been filed by the assessee against the final judgment and order dated 6th October 2001 passed by the High Court of Karnataka at Bangalore in ITRC Nos. 684/98, 685/98, 686/98 and 687/98 by which the High Court while setting aside the order of assessment passed by the Income Tax Appellate Tribunal (for short, ‘the Tribunal’) and that of the Commissioner of Income Tax (Appeals), held that the facts and circumstances of the case warranted levy of penalty under Section 271(1)(c) of the Income Tax Act, 1961 (for short “the Act”).

2. The assessment years involved in the present Appeals are 1984-85, 1985-86, 1986-87 and 1987-88.

Facts:

3. A search was conducted on the premises of the assesses on 14th and 15th of October, 1987 and incriminating documents evidencing concealment of income by the assessee were unearthed apart from cash and jewellery found at the time of search. It was found that the appellant was maintaining double set of books and was accounting for only 50% of sales in the regular set of books. This fact was admitted by Shri J.S. Ramesh, a partner of the firm in the statement recorded under Section 132(4) of the Act. Shri J.S. R