https://www.taxtmi.com/caselaws?id=276270 Penalty under section 28(1)(c) of the Income-tax Act, 1922 is penal in nature, so the revenue must prove concealment of income or deliberate furnishing of inaccurate particulars. A mere rejection of the assessee's explanation in assessment proceedings, or an adverse inference that the source of an investment was not satisfactorily explained, is not enough by itself to establish wilful concealment. Where the record does not show a positive finding of wilful suppression and the department fails to discharge its burden, no penalty is imposable under the provision. en-us Thu, 12 Sep 1963 00:00:00 +0530 Sat, 03 Nov 2018 18:33:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276270 Penalty under section 28(1)(c) of the Income-tax Act, 1922 is penal in nature, so the revenue must prove concealment of income or deliberate furnishing of inaccurate particulars. A mere rejection of the assessee's explanation in assessment proceedings, or an adverse inference that the source of an investment was not satisfactorily explained, is not enough by itself to establish wilful concealment. Where the record does not show a positive finding of wilful suppression and the department fails to discharge its burden, no penalty is imposable under the provision. Case-Laws Income Tax Thu, 12 Sep 1963 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276270