https://www.taxtmi.com/caselaws?id=13711 Penalty under section 271(1)(c) was found unsustainable because the Tribunal and lower authorities recorded concurrent facts that the Revenue had not proved concealment of income, fraud, gross neglect, or wilful neglect. The material relied upon was insufficient to discharge the onus under Explanation 1, and an earlier surrender of income at a higher commission rate in other years before the Settlement Commission did not, by itself, establish deliberate concealment for the years in dispute, especially where the Revenue later accepted commission at 1%. The High Court therefore treated the findings as factual and concluded that no substantial question of law arose in the Revenue's appeals. en-us Mon, 17 Jul 2006 00:00:00 +0530 Sun, 06 Feb 2011 02:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13711 Penalty under section 271(1)(c) was found unsustainable because the Tribunal and lower authorities recorded concurrent facts that the Revenue had not proved concealment of income, fraud, gross neglect, or wilful neglect. The material relied upon was insufficient to discharge the onus under Explanation 1, and an earlier surrender of income at a higher commission rate in other years before the Settlement Commission did not, by itself, establish deliberate concealment for the years in dispute, especially where the Revenue later accepted commission at 1%. The High Court therefore treated the findings as factual and concluded that no substantial question of law arose in the Revenue's appeals. Case-Laws Income Tax Mon, 17 Jul 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13711