https://www.taxtmi.com/caselaws?id=12298 Penalty under s. 271(1)(c) was upheld where undisclosed cash was added under s. 69A and the assessee failed to furnish any explanation in response to the penalty show-cause notice. The HC held that Explanation 1 to s. 271(1)(c) is not a rebuttable presumption to initiate enquiry; it operates after enquiry when conditions in cl. (A) or (B) exist, and applies automatically without needing express invocation by the AO. On facts, authorities concurrently found no explanation in penalty proceedings and, even treating the assessment-stage explanation as relevant, it was found false; this was a factual finding based on evidence raising no substantial question of law. The appeal was dismissed. en-us Fri, 14 Sep 2001 00:00:00 +0530 Tue, 06 Jan 2026 22:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12298 Penalty under s. 271(1)(c) was upheld where undisclosed cash was added under s. 69A and the assessee failed to furnish any explanation in response to the penalty show-cause notice. The HC held that Explanation 1 to s. 271(1)(c) is not a rebuttable presumption to initiate enquiry; it operates after enquiry when conditions in cl. (A) or (B) exist, and applies automatically without needing express invocation by the AO. On facts, authorities concurrently found no explanation in penalty proceedings and, even treating the assessment-stage explanation as relevant, it was found false; this was a factual finding based on evidence raising no substantial question of law. The appeal was dismissed. Case-Laws Income Tax Fri, 14 Sep 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12298