Sandhawalia, J.

1. Whether the ratio of CIT V/s. Anwar Ali [1970] 76 ITR 696 (SC) still holds the field despite the designed deletion of the word "deliberately" from Section 271(1)(c) of the I.T. Act, 1961, and the pointed insertion of an exhaustive Explanation thereto by the Finance Act No. 5 of 1964 has come to be the focal question in this reference to the Full Bench. Equally at issue is the correctness of either one of the two strands of parallel judicial thought within this court itself.

2. Somewhat regretfully it must be noticed that the issues aforesaid arise from an assessment made way back for the year 1964-65. The assessee, M/s. Nathulal Agrawala & Sons, Hazaribagh, had declared its income at merely Rs. 22,116. The ITO, however, completed the assessment at a nearly four-fold figure of Rs. 82,378. He included in this assessment a sum of Rs. 26,000 purporting to be in the names of the wives of three of the partners of the assessee firm. Admittedly, the ITO had required the assessee to explain the nature and sources of these alleged cash credits. This was said to be furnished by the assessee but the same was categorically rejected and an amount of Rs. 26,000 was adde