https://www.taxtmi.com/caselaws?id=177797 Penalty under s 271(1)(c) was in issue where additional income was offered only after detection in reassessment proceedings. The HC held that "concealment" and "furnishing inaccurate particulars" under s 271(1)(c) do not require proof of deliberateness, as the statutory term "deliberately" was deleted with effect from 1 April 1964. It further held that a surrender in a purported revised return, when prompted by detection, is not voluntary and is of no consequence; "omission" connotes an intentional act, and the disclosure was merely a veiled attempt to mitigate. A return filed pursuant to s 148 cannot be equated with a revised return for claiming mitigation. Penalty was upheld; issue answered for the Revenue. en-us Fri, 15 Oct 1999 00:00:00 +0530 Sat, 20 Dec 2025 00:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177797 Penalty under s 271(1)(c) was in issue where additional income was offered only after detection in reassessment proceedings. The HC held that "concealment" and "furnishing inaccurate particulars" under s 271(1)(c) do not require proof of deliberateness, as the statutory term "deliberately" was deleted with effect from 1 April 1964. It further held that a surrender in a purported revised return, when prompted by detection, is not voluntary and is of no consequence; "omission" connotes an intentional act, and the disclosure was merely a veiled attempt to mitigate. A return filed pursuant to s 148 cannot be equated with a revised return for claiming mitigation. Penalty was upheld; issue answered for the Revenue. Case-Laws Income Tax Fri, 15 Oct 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177797