https://www.taxtmi.com/caselaws?id=6319 Penalty for concealment or furnishing inaccurate particulars is penal in character and requires cogent material showing both that the disputed amount was income and that the assessee consciously concealed particulars or deliberately furnished inaccurate particulars. An assessment order may be relevant evidence, but it cannot by itself sustain the penalty. On the stated facts, the Tribunal treated the additions as based only on suspicion and found no independent material proving conscious concealment; those were factual findings. The penalty therefore could not be sustained on the assessment reasoning alone, and no question of law arose for reference. en-us Wed, 22 Sep 1971 00:00:00 +0530 Wed, 01 Jul 2026 15:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6319 Penalty for concealment or furnishing inaccurate particulars is penal in character and requires cogent material showing both that the disputed amount was income and that the assessee consciously concealed particulars or deliberately furnished inaccurate particulars. An assessment order may be relevant evidence, but it cannot by itself sustain the penalty. On the stated facts, the Tribunal treated the additions as based only on suspicion and found no independent material proving conscious concealment; those were factual findings. The penalty therefore could not be sustained on the assessment reasoning alone, and no question of law arose for reference. Case-Laws Income Tax Wed, 22 Sep 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6319