Penalty for concealment fails when reassessment adds nothing and no clear finding of inaccurate particulars exists.

Penalty under section 271(1)(c) could not be sustained where the reassessment return under section 148 was accepted without any addition and no clear finding was recorded that the assessee had concealed income or furnished inaccurate particulars. In the absence of both an assessed addition and a categorical concealment finding, the factual foundation for penalty failed, so the penalty was deleted.

---

---

Issues: Whether penalty under section 271(1)(c) of the Income-tax Act, 1961 was sustainable when no addition had been made in the reassessment and no categorical finding of concealment or furnishing of inaccurate particulars had been recorded.

Analysis: The assessee's return filed under section 148 had been accepted without any addition. In such circumstances, the essential factual foundation for sustaining penalty was absent, and the lower authorities had not recorded a clear finding that the assessee had concealed income or furnished inaccurate particulars of income.

Conclusion: The penalty was not sustainable and was directed to be deleted.

---