https://www.taxtmi.com/caselaws?id=188833 Findings recorded in assessment proceedings may be used as relevant material in penalty proceedings under the Income-tax Act, 1922, because there is no rule excluding them from consideration. However, those findings do not operate as res judicata in penalty proceedings, since assessment and penalty involve different inquiries: assessment determines taxable income, while penalty requires a finding of concealment or deliberate furnishing of inaccurate particulars. The assessment findings are therefore evidentiary, not binding, in subsequent penalty proceedings. en-us Wed, 01 Apr 1953 00:00:00 +0530 Sat, 17 Dec 2016 12:53:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=188833 Findings recorded in assessment proceedings may be used as relevant material in penalty proceedings under the Income-tax Act, 1922, because there is no rule excluding them from consideration. However, those findings do not operate as res judicata in penalty proceedings, since assessment and penalty involve different inquiries: assessment determines taxable income, while penalty requires a finding of concealment or deliberate furnishing of inaccurate particulars. The assessment findings are therefore evidentiary, not binding, in subsequent penalty proceedings. Case-Laws Income Tax Wed, 01 Apr 1953 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=188833