Concealment penalty sustained for undisclosed rent receipts after repeated non-disclosure and rejected bona fide explanation.

Penalty under section 271(1)(c) was upheld where assessees failed to file returns, undisclosed rent receipts came to light only after investigation and notice under section 148, and the quantum additions had attained finality. The record showed regular monthly rent receipts that were not disclosed for several years, and the explanations of ignorance, confusion over the character of income, and bona fides were rejected as unsupported by the conduct and facts. The repeated non-disclosure was treated as deliberate suppression and conscious concealment, supporting penalty for concealment of income and furnishing inaccurate particulars.

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Issues: Whether penalty under section 271(1)(c) of the Income-tax Act, 1961 was sustainable for concealment of income and furnishing of inaccurate particulars in respect of the assessees' undisclosed rent receipts and deposits.

Analysis: The assessees had not filed returns for the relevant years and the income came to light only after investigation and issuance of notice under section 148. The additions in the quantum proceedings had attained finality as no appeal was pursued. The record showed that the assessees were regularly receiving monthly rent from the property, yet the receipts were not disclosed for several years. The explanation of ignorance, confusion about the character of income, and bona fides was rejected as unsupported by the facts and conduct of the assessees. The repeated non-disclosure was treated as deliberate suppression and conscious concealment, not a voluntary or bona fide default.

Conclusion: The penalty under section 271(1)(c) was rightly imposed and confirmed. The issue was decided against the assessees and in favour of the Revenue.

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