Penalty for unexplained cash credits sustained where concealment findings were supported by material and not shown to be perverse.

Penalty under section 271(1)(c) was treated as sustainable where the assessee failed to explain cash credits, did not produce the creditors, and could not establish the genuineness of the transactions despite opportunity. The concealment finding was supported by material and was not shown to be perverse or erroneous, so the challenge to penalty failed. On those facts, the matter did not raise any substantial question of law under section 260A.

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Issues: Whether the penalty under section 271(1)(c) of the Income-tax Act, 1961 was rightly imposed for concealment of income and furnishing of inaccurate particulars where the assessee failed to explain cash credits.

Analysis: The addition made in assessment, including the unexplained cash credits, was sustained by the appellate authorities. The assessee failed to produce the creditors or establish the genuineness of the transactions despite opportunity. The findings of concealment were not shown to be perverse or erroneous. On these facts, the case fell within the scope of penalty for concealment under section 271(1)(c), and no substantial question of law arose for consideration under section 260A.

Conclusion: The penalty was held to be valid and the challenge to its imposition failed.

Ratio Decidendi: Where the assessee fails to discharge the burden of explaining cash credits and the findings of concealment are supported by material and not shown to be perverse, penalty under section 271(1)(c) is sustainable and does not give rise to a substantial question of law.

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