https://www.taxtmi.com/caselaws?id=17285 Penalty under section 271(1)(c) was not sustainable where the assessee had disclosed the income for the full year and the real dispute concerned whether the business was carried on as an individual concern up to 26 August 1967 or as a partnership from 1 April 1967. The partnership deed supported commencement from 1 April 1967, while the Revenue relied on alleged book interpolations to contend otherwise. Because the facts admitted two possible views, the mere possibility of assessment in the assessee's individual hands did not establish concealment of income. The cancellation of penalty was therefore justified, and no concealment was found. en-us Thu, 03 Jul 1997 00:00:00 +0530 Mon, 21 Sep 2009 13:09:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=17285 Penalty under section 271(1)(c) was not sustainable where the assessee had disclosed the income for the full year and the real dispute concerned whether the business was carried on as an individual concern up to 26 August 1967 or as a partnership from 1 April 1967. The partnership deed supported commencement from 1 April 1967, while the Revenue relied on alleged book interpolations to contend otherwise. Because the facts admitted two possible views, the mere possibility of assessment in the assessee's individual hands did not establish concealment of income. The cancellation of penalty was therefore justified, and no concealment was found. Case-Laws Income Tax Thu, 03 Jul 1997 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=17285