https://www.taxtmi.com/caselaws?id=8163 In concealment penalty proceedings, the department must establish on the totality of circumstances that the disputed receipt was income and that the assessee consciously concealed particulars or deliberately furnished inaccurate particulars. The Tribunal had accepted the assessee's prima facie explanation that the credits represented sale proceeds of ornaments and found no sufficient rebuttal by the department; that was treated as a factual finding, and a mere rejection of the explanation did not by itself prove concealment. The Court held that no question of law arose for reference and dismissed the application. en-us Thu, 25 Mar 1971 00:00:00 +0530 Tue, 31 Mar 2009 16:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8163 In concealment penalty proceedings, the department must establish on the totality of circumstances that the disputed receipt was income and that the assessee consciously concealed particulars or deliberately furnished inaccurate particulars. The Tribunal had accepted the assessee's prima facie explanation that the credits represented sale proceeds of ornaments and found no sufficient rebuttal by the department; that was treated as a factual finding, and a mere rejection of the explanation did not by itself prove concealment. The Court held that no question of law arose for reference and dismissed the application. Case-Laws Income Tax Thu, 25 Mar 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8163