Penalty under section 22(6)(b) fails without proper inquiry and verified admissions before levy.

Penalty under section 22(6)(b) could not be sustained where the assessee's statements were not properly verified and the required inquiry was not conducted before levy. The record did not show that the statements had been read over and accepted, and the assessee's signatures on the proceeding sheet and statements were treated as insufficient to establish a valid admission. The assessing authority was required to verify the material and establish the case through a proper inquiry before imposing penalty. The penalty was therefore quashed and the revision failed.

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Issues: Whether the penalty levied under section 22(6) could be sustained when the assessee's statements were not properly verified and no effective inquiry was made before imposition of penalty.

Analysis: The statements on record were not verified as having been read over and accepted, and the assessee's signatures on the proceeding sheet and statements gave a prima facie impression that the process had not been properly completed. Section 22(6)(b) required an inquiry before penalty could be levied. In the absence of a proper admission by the assessee, the assessing authority was obliged to establish the case before imposing penalty.

Conclusion: The penalty was rightly quashed and no interference was called for.

Final Conclusion: The revision failed and the penalty order did not survive.

Ratio Decidendi: A penalty under section 22(6)(b) cannot be sustained unless the assessing authority conducts the required inquiry and bases the levy on properly verified material or a valid admission.

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