https://www.taxtmi.com/caselaws?id=9329 Explanation to section 271(1)(c) addresses a statutory presumption of concealment where returned income and assessed income disparity exists; the presumption is rebuttable and its rebuttal depends on the totality of facts and cumulative evidence, not any single item. Failure to maintain proper accounting and reliance on estimates were considered against the presumption, but completeness and correctness of accounts under the proviso to section 145(1) is a relevant factor in assessing fraud, wilful or gross neglect; the material record may suffice to rebut the presumption and thereby negate imposition of penalty in individual cases. en-us Tue, 24 Apr 1973 00:00:00 +0530 Tue, 27 Jan 2026 13:15:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9329 Explanation to section 271(1)(c) addresses a statutory presumption of concealment where returned income and assessed income disparity exists; the presumption is rebuttable and its rebuttal depends on the totality of facts and cumulative evidence, not any single item. Failure to maintain proper accounting and reliance on estimates were considered against the presumption, but completeness and correctness of accounts under the proviso to section 145(1) is a relevant factor in assessing fraud, wilful or gross neglect; the material record may suffice to rebut the presumption and thereby negate imposition of penalty in individual cases. Case-Laws Income Tax Tue, 24 Apr 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9329