Penalty for concealment requires recorded satisfaction; a tax computation error without such finding will not sustain section 271(1)(c).

Penalty under section 271(1)(c) requires a recorded finding that the assessee concealed income or furnished inaccurate particulars. Where the assessment order contains no such satisfaction, and the dispute arises from omission in compliance with minimum alternate tax requirements under section 115JB, penalty is not sustainable. The materials disclosed the relevant figures and computation details, and the omission was treated as a legal or accounting error rather than deliberate concealment. Mere acceptance of the assessment or payment of tax does not, by itself, justify penalty. In the absence of a finding of concealment or inaccuracy, the penalty order was set aside.

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Issues: Whether penalty under section 271(1)(c) of the Income-tax Act, 1961 could be sustained when the assessment order contained no finding that the assessee had concealed income or furnished inaccurate particulars and the dispute arose from omission relating to minimum alternate tax under section 115JB.

Analysis: For penalty under section 271(1)(c), the precondition is a finding that the assessee concealed particulars of income or furnished inaccurate particulars. The assessment order did not record any such finding; instead, the penalty was triggered because the assessee had not filed Form 29B and had not initially paid tax under section 115JB. The return and assessment materials showed that the relevant figures and computation details were disclosed, and the omission was treated as a legal and accounting mistake rather than a deliberate furnishing of false particulars. Mere acceptance of the quantum assessment and payment of tax did not automatically justify penalty. In the absence of a recorded satisfaction of concealment or inaccuracy, the penalty could not stand.

Conclusion: The penalty under section 271(1)(c) was unsustainable and was set aside; the question of law was answered in favour of the assessee.

Final Conclusion: The appellate court interfered with the concurrent penalty orders and granted relief to the assessee, holding that the statutory requirements for penalty were not satisfied.

Ratio Decidendi: Penalty under section 271(1)(c) cannot be imposed unless the assessing authority records a finding of concealment of income or furnishing of inaccurate particulars; a mere tax computation error or omission without such finding is insufficient.

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