https://www.taxtmi.com/caselaws?id=70534 Penalty for concealment of income under Section 271(1)(c) could not be sustained merely because the assessee's explanation for a credit was rejected in assessment proceedings. The material on record did not show that the explanation was inherently false, improbable, artificial or unnatural, and the statutory Explanation could be applied only where fraud, gross neglect or wilful neglect was established. The distinction between assessment and penalty proceedings was material, and additional evidence of culpable conduct was required before concealment could be inferred. On that basis, cancellation of the penalty was upheld in favour of the assessee. en-us Wed, 14 Feb 1979 00:00:00 +0530 Sat, 16 Apr 2011 16:15:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70534 Penalty for concealment of income under Section 271(1)(c) could not be sustained merely because the assessee's explanation for a credit was rejected in assessment proceedings. The material on record did not show that the explanation was inherently false, improbable, artificial or unnatural, and the statutory Explanation could be applied only where fraud, gross neglect or wilful neglect was established. The distinction between assessment and penalty proceedings was material, and additional evidence of culpable conduct was required before concealment could be inferred. On that basis, cancellation of the penalty was upheld in favour of the assessee. Case-Laws Income Tax Wed, 14 Feb 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70534