https://www.taxtmi.com/caselaws?id=246199 Explanation 5 to Section 271(1)(c) creates a deeming fiction of concealment in search cases, but its immunity applies where the assessee admits undisclosed income in a Section 132(4) statement, offers it to tax, and pays tax and interest. The court treated the Revenue's objection that the manner of deriving the income was not specifically stated as hypertechnical, and held that substantial compliance with the disclosure requirement was sufficient. On that basis, the penalty under Section 271(1)(c) was held not sustainable. en-us Tue, 01 Apr 2014 00:00:00 +0530 Fri, 18 Apr 2014 16:04:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=246199 Explanation 5 to Section 271(1)(c) creates a deeming fiction of concealment in search cases, but its immunity applies where the assessee admits undisclosed income in a Section 132(4) statement, offers it to tax, and pays tax and interest. The court treated the Revenue's objection that the manner of deriving the income was not specifically stated as hypertechnical, and held that substantial compliance with the disclosure requirement was sufficient. On that basis, the penalty under Section 271(1)(c) was held not sustainable. Case-Laws Income Tax Tue, 01 Apr 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=246199