Concealment of Income

[pradip shah]

When the assessee has furnished during assessment proceedings, the details of Share Application Money as well as Unsecured Loans received by the company, which could not be substaniated further in assessment ans as such have been added as income U/s 68. Thereafter on such additions concealment penalty also have been levied. Is there any strong submission for this or case law to be submitted in defence before CIT appeals so that the penalty is deleted.

AI Summary

Penalty Challenged Under Section 68: Importance of Substantiation in Share Application Money and Unsecured Loans Case An individual inquired about a concealment penalty levied under Section 68 of the Income Tax Act after their company failed to substantiate details of Share Application Money and Unsecured Loans during assessment proceedings. The penalty was imposed due to these amounts being added as income. A respondent highlighted the importance of understanding why substantiation was not possible, suggesting that undisclosed investments by share applicants or loan creditors should not automatically result in the recipient being assumed to have undisclosed income. The respondent implied that this reasoning could be used in defense before the CIT appeals to seek penalty deletion.