https://www.taxtmi.com/caselaws?id=210119 HC held that penalty under s.271(1)(c) could not be imposed where the taxpayer had voluntarily surrendered the amount, made complete disclosure in the return and offered the amount to tax; penal provision must be strictly construed and cannot rest on presumptions or conjecture. Exposure during a survey does not automatically establish concealment or permit penalty, and the conditions of s.271(1)(c) were not unambiguously satisfied. Decision: penalty set aside in favour of the assessee. en-us Fri, 08 Apr 2011 00:00:00 +0530 Fri, 22 Aug 2025 14:34:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210119 HC held that penalty under s.271(1)(c) could not be imposed where the taxpayer had voluntarily surrendered the amount, made complete disclosure in the return and offered the amount to tax; penal provision must be strictly construed and cannot rest on presumptions or conjecture. Exposure during a survey does not automatically establish concealment or permit penalty, and the conditions of s.271(1)(c) were not unambiguously satisfied. Decision: penalty set aside in favour of the assessee. Case-Laws Income Tax Fri, 08 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210119