Concealment penalty must track proved suppression, not the full assessed addition where part rests on estimate.

Penalty for concealment must be confined to the income actually proved to have been concealed, not the full addition sustained in assessment. Because only part of the suppressed sales was established and the balance of the income addition was based on estimate, the entire enhanced income could not be treated as concealed income for penalty purposes. The penalty was therefore sustainable only to the extent of the concealment actually proved.

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Issues: Whether penalty for concealment was leviable with reference to the amount actually found to have been concealed or with reference to the entire addition sustained in the quantum assessment.

Analysis: The addition in the assessment was not wholly founded on proved concealment; only a part of the suppressed sales was established, while the balance of the income addition rested on estimate. On the facts found, the material on record did not justify treating the whole enhanced income as concealed income for penalty purposes.

Conclusion: The penalty could be sustained only to the extent of the concealment actually proved, and not on the entire extra profit addition.

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