Revised return does not cure deliberate concealment where the original filing contained false particulars and explanation lacked bona fides.

Penalty under section 271(1)(c) of the Income-tax Act was held sustainable where revised returns were filed after a search but the original omission was found to be deliberate rather than accidental or bona fide. The court reiterated that a later revised return does not erase earlier concealment or false particulars, and the decisive question is whether income was intentionally concealed at any stage. Acceptance of the revised return did not bar penalty because the explanation failed to satisfactorily negate concealment and the authorities had recorded genuine satisfaction on the material before them.

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Issues: Whether penalty under section 271(1)(c) of the Income-tax Act, 1961 was exigible where the assessee filed revised returns offering amounts as non-taxable income before notice under section 148, and whether the disclosure was bona fide so as to negate concealment or furnishing of inaccurate particulars.

Analysis: The revised returns were filed after a search and the factual finding was that the omission in the original returns was not accidental, bona fide, or due to inadvertence. The Court followed its earlier view that the later filing of a revised return does not wash out an earlier deliberate concealment, and that the real question is whether the assessee had, at any time, intentionally concealed income or furnished false particulars. It also reiterated that acceptance of a revised return does not bar penalty where the explanation does not satisfactorily show absence of concealment and where the authorities have recorded a genuine satisfaction on the materials before them.

Conclusion: The penalty was rightly sustained and the issue was answered against the assessee.

Final Conclusion: The appeals failed on merits, and the penalty order was upheld.

Ratio Decidendi: A later revised return does not defeat penalty under section 271(1)(c) where the original return involved deliberate concealment or furnishing of false particulars, and penalty can be sustained if the explanation fails to show bona fide disclosure.

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