https://www.taxtmi.com/caselaws?id=62430 The Explanation to section 271(1)(c) applied to penalty proceedings initiated after the relevant dates, so the burden shifted to the assessee to offer a probable explanation for the source of the invested or concealed amounts. Where the assessee could trace part of the to earlier returns, that explained portion could not be penalised. However, for the balance amounts for which no satisfactory source was shown, the onus under the Explanation was not discharged and penalty survived only to that extent. The excess penalty was therefore not sustainable and was to be reduced accordingly. en-us Fri, 19 Aug 1977 00:00:00 +0530 Wed, 19 Jan 2011 17:58:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62430 The Explanation to section 271(1)(c) applied to penalty proceedings initiated after the relevant dates, so the burden shifted to the assessee to offer a probable explanation for the source of the invested or concealed amounts. Where the assessee could trace part of the to earlier returns, that explained portion could not be penalised. However, for the balance amounts for which no satisfactory source was shown, the onus under the Explanation was not discharged and penalty survived only to that extent. The excess penalty was therefore not sustainable and was to be reduced accordingly. Case-Laws Income Tax Fri, 19 Aug 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62430