https://www.taxtmi.com/caselaws?id=5251 Possession of unexplained valuable articles may support a presumption of ownership, and where no credible explanation of source is offered, their value can be treated as deemed income under the unexplained assets provision. The commentary also explains that, for concealment penalty purposes, if returned income falls below the statutory threshold against assessed income, the penalty explanation shifts the burden to the assessee to rebut the presumption of concealment and show absence of fraud, gross neglect, or wilful neglect. On the stated facts, both the addition and the concealment penalty were sustained. en-us Mon, 02 May 1988 00:00:00 +0530 Tue, 03 Feb 2026 17:29:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5251 Possession of unexplained valuable articles may support a presumption of ownership, and where no credible explanation of source is offered, their value can be treated as deemed income under the unexplained assets provision. The commentary also explains that, for concealment penalty purposes, if returned income falls below the statutory threshold against assessed income, the penalty explanation shifts the burden to the assessee to rebut the presumption of concealment and show absence of fraud, gross neglect, or wilful neglect. On the stated facts, both the addition and the concealment penalty were sustained. Case-Laws Income Tax Mon, 02 May 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5251