Inadvertent omission of bank interest income did not justify penalty absent proof of concealment or inaccurate particulars.

Penalty under section 271(1)(c) was held unsustainable where the assessee's failure to disclose bank interest income was treated as an inadvertent oversight rather than concealment. The explanation that the omission was unintentional, including the assessee's circumstances after taking over the business following her husband's death, was accepted. The Department did not establish furnishing of inaccurate particulars or deliberate suppression of income, and the penalty was cancelled.

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Issues: Whether the penalty imposed under section 271(1)(c) of the Income-tax Act was sustainable where the assessee omitted to include bank interest income in the original return and claimed the omission was inadvertent.

Analysis: The omission was found to be a matter of oversight rather than deliberate concealment. The addition in reassessment was only a small amount compared with the assessed income, and the explanation that the assessee, a widow who had taken over the business after her husband's death, had not intentionally suppressed the interest income was accepted. The Department failed to establish concealment of income or furnishing of inaccurate particulars.

Conclusion: The penalty under section 271(1)(c) was not justified and was cancelled.

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