HC upheld penalty under s271(1)(c) for concealment of income...

HC upheld penalty under s271(1)(c) for concealment of income where appellant transferred stock-in-trade at inflated market value and withdrew profits without full disclosure. The formation of firm and transaction pattern constituted a tax evasion scheme. Mere filing of capital account with returns was deemed insufficient for true disclosure. Court found appellant's explanation patently false and unsubstantiated as bona fide. Despite Explanation 1 to s147 being inapplicable, Explanation 1 to s271 supported penalty imposition. The minimum prescribed penalty was justified given the deliberate device adopted to evade taxes, and the finality of income addition assessment. Appeal dismissed.