https://www.taxtmi.com/caselaws?id=14003 HC held that the concealment of income did not fall within clause (c) of Explanation 4 to s.271(1)(c) where the Assessing Officer had not tested and rejected the assessee's explanation and had merely substituted an estimated figure for trading results. Explanation 1 only conferred jurisdiction and could not serve as conclusive proof to discard the assessee's bona fides. Substitution of an estimated sum is neither an addition of a specific undeclared amount nor a disallowance of a claimed deduction; accordingly the penalty under s.271(1)(c) was not attracted, decision for the assessee. en-us Mon, 05 Feb 2001 00:00:00 +0530 Mon, 06 Oct 2025 15:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14003 HC held that the concealment of income did not fall within clause (c) of Explanation 4 to s.271(1)(c) where the Assessing Officer had not tested and rejected the assessee's explanation and had merely substituted an estimated figure for trading results. Explanation 1 only conferred jurisdiction and could not serve as conclusive proof to discard the assessee's bona fides. Substitution of an estimated sum is neither an addition of a specific undeclared amount nor a disallowance of a claimed deduction; accordingly the penalty under s.271(1)(c) was not attracted, decision for the assessee. Case-Laws Income Tax Mon, 05 Feb 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14003