https://www.taxtmi.com/caselaws?id=9051 Penalty under section 271(1)(c) requires proof of concealment on the stricter penal standard; assessment of an amount as income does not, by itself, establish liability for penalty. The Explanation may shift the burden where returned income falls below the prescribed threshold, but it does not remove the Revenue's obligation to show that the amount was in fact the assessee's concealed income. Unexplained cash and rejection of the assessee's explanation may justify assessment, yet still fall short of the material needed for penalty. As the assessee's ownership of the money was not proved and the Revenue did no more than reject the explanation, concealment was not established and penalty was held not leviable. en-us Mon, 29 Oct 1973 00:00:00 +0530 Thu, 18 Jun 2009 19:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9051 Penalty under section 271(1)(c) requires proof of concealment on the stricter penal standard; assessment of an amount as income does not, by itself, establish liability for penalty. The Explanation may shift the burden where returned income falls below the prescribed threshold, but it does not remove the Revenue's obligation to show that the amount was in fact the assessee's concealed income. Unexplained cash and rejection of the assessee's explanation may justify assessment, yet still fall short of the material needed for penalty. As the assessee's ownership of the money was not proved and the Revenue did no more than reject the explanation, concealment was not established and penalty was held not leviable. Case-Laws Income Tax Mon, 29 Oct 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9051