N. Kumar, J.”A batch of appeals where different facets of Section 271 of the Income Tax Act, 1961 are involved, were placed before us. Therefore, we heard all the learned counsel appearing in the batch of cases, considered all the arguments addressed and interpreted Section 271 in its different facets and have laid down the law.

FACTUAL MATRIX

FACTS IN ITA Nos. 2564 & 2565/2005

The facts of this case are as under:-

The assessee-firm in ITA No. 2564/2005 is in the business of purchasing kapas and converting it into cotton in the ginning factory owned by it and trades in cotton and cotton seeds. The assessee had filed the return of income for the assessment year 2000-01 declaring total income of Rs. 2,29,520/-. A survey under Section 133A of the Income Tax Act (for short hereinafter referred to as "the Act") was conducted in the business premises of the assessee on 23.11.2000. During the course of survey, a notebook was found in the business premises of the assessee, wherein certain transactions carried were noted. These transactions pertains to four cases showing names and amounts. The total of the transactions amounted to Rs. 7,98,200/-. The partner of the assessee-firm explain