https://www.taxtmi.com/caselaws?id=63511 Concealment penalty under section 271(1)(c) is governed by the law in force on the date of the offending return, so later amendment does not change the basis for levy or quantification. In penalty proceedings, the revenue must prove conscious concealment of taxable income or furnishing of inaccurate particulars; mere rejection of the assessee's explanation is insufficient. An addition based only on estimates, including differing construction-cost estimates, does not by itself establish concealment. On the stated facts, penalty was not exigible on either reassessment addition. en-us Wed, 09 Mar 1994 00:00:00 +0530 Mon, 31 Jan 2011 14:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=63511 Concealment penalty under section 271(1)(c) is governed by the law in force on the date of the offending return, so later amendment does not change the basis for levy or quantification. In penalty proceedings, the revenue must prove conscious concealment of taxable income or furnishing of inaccurate particulars; mere rejection of the assessee's explanation is insufficient. An addition based only on estimates, including differing construction-cost estimates, does not by itself establish concealment. On the stated facts, penalty was not exigible on either reassessment addition. Case-Laws Income Tax Wed, 09 Mar 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=63511