https://www.taxtmi.com/caselaws?id=220469 Penalty under section 271(1)(c) was sustained because the assessee surrendered income without furnishing any explanation of the nature and source of the amount. Explanation 1 applied where no explanation was offered, or where an explanation was unsubstantiated and not shown to be bona fide with full disclosure of material facts. The nature and source of the surrendered amount were facts within the assessee's special knowledge, and the absence of any explanation triggered the statutory deeming fiction of concealment. The Tribunal erred in treating the surrender itself as sufficient to delete the penalty. The substantial question of law was answered in favour of the Revenue. en-us Tue, 22 Jan 2013 00:00:00 +0530 Fri, 28 Jun 2013 15:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=220469 Penalty under section 271(1)(c) was sustained because the assessee surrendered income without furnishing any explanation of the nature and source of the amount. Explanation 1 applied where no explanation was offered, or where an explanation was unsubstantiated and not shown to be bona fide with full disclosure of material facts. The nature and source of the surrendered amount were facts within the assessee's special knowledge, and the absence of any explanation triggered the statutory deeming fiction of concealment. The Tribunal erred in treating the surrender itself as sufficient to delete the penalty. The substantial question of law was answered in favour of the Revenue. Case-Laws Income Tax Tue, 22 Jan 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=220469