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Penalty for unexplained fixed-deposit credits is not warranted...
Bona fide public fixed-deposit explanations prevent concealment penalties where unexplained-credit additions lack independent evidence of undisclosed income.
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Penalty for unexplained fixed-deposit credits is not warranted merely because an addition is sustained under the deeming provision for unexplained credits when deposits were accepted under a public fixed-deposit scheme. Depositor particulars, supporting records, and an explanation that certain deposits were renewals supported the bona fides of the explanation. Without independent material establishing that the deposits represented undisclosed income, the addition alone did not justify concealment penalty. The penalty was deleted, while remaining grounds were left open as academic.
Penalty for unexplained fixed-deposit credits is not warranted merely because an addition is sustained under the deeming provision for unexplained credits when deposits were accepted under a public fixed-deposit scheme. Depositor particulars, supporting records, and an explanation that certain deposits were renewals supported the bona fides of the explanation. Without independent material establishing that the deposits represented undisclosed income, the addition alone did not justify concealment penalty. The penalty was deleted, while remaining grounds were left open as academic.
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