Penalty under section 271(1)(c) was upheld because the assessee...

Penalty under section 271(1)(c) was upheld because the assessee failed to substantiate that the investment came from exempt agricultural income or any other explained source. No cogent documentary evidence was produced despite opportunities during assessment, penalty, and appellate proceedings, and the income was not disclosed in the original return or the return filed under section 148. The disclosure arose only after departmental detection in reassessment, so it was treated as non-voluntary. The plea of surrender to buy peace did not bar penalty, and Explanation 1 to section 271(1)(c) applied because bona fides and substantiation were not established.

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