https://www.taxtmi.com/caselaws?id=12268 The HC set aside imposition of penalty under s.271(1)(c), holding that additions were based on differing estimates by AO and Tribunal and did not establish concealment or furnishing of inaccurate particulars. There was no evidence income exceeded the return; estimates alone do not prove concealment, and the burden to show a positive act of concealment lay on the Department. The Tribunal erred in invoking Explanation 1B to raise a presumption. The taxpayer had substantiated estimates by reference to household expenditure and investments, and the explanation was found to be bona fide. en-us Wed, 21 Aug 2002 00:00:00 +0530 Tue, 30 Sep 2025 15:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12268 The HC set aside imposition of penalty under s.271(1)(c), holding that additions were based on differing estimates by AO and Tribunal and did not establish concealment or furnishing of inaccurate particulars. There was no evidence income exceeded the return; estimates alone do not prove concealment, and the burden to show a positive act of concealment lay on the Department. The Tribunal erred in invoking Explanation 1B to raise a presumption. The taxpayer had substantiated estimates by reference to household expenditure and investments, and the explanation was found to be bona fide. Case-Laws Income Tax Wed, 21 Aug 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12268