https://www.taxtmi.com/caselaws?id=15047 Penalty for concealment could not be sustained where the assessee's explanation was not found false and the material facts were fully disclosed. The amended deeming provision under section 271(1)(c) applies when no explanation is offered, the explanation is false, or it remains unsubstantiated, but the proviso protects a bona fide explanation supported by full disclosure. On the quantum findings, the commission payment was disallowed under section 40(b), yet the existence of the company, the agreement, and the payment itself were not treated as fabricated. Penalty was therefore held not leviable. en-us Sat, 27 Nov 1999 00:00:00 +0530 Mon, 27 Jul 2009 18:14:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15047 Penalty for concealment could not be sustained where the assessee's explanation was not found false and the material facts were fully disclosed. The amended deeming provision under section 271(1)(c) applies when no explanation is offered, the explanation is false, or it remains unsubstantiated, but the proviso protects a bona fide explanation supported by full disclosure. On the quantum findings, the commission payment was disallowed under section 40(b), yet the existence of the company, the agreement, and the payment itself were not treated as fabricated. Penalty was therefore held not leviable. Case-Laws Income Tax Sat, 27 Nov 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15047