https://www.taxtmi.com/caselaws?id=18305 HC held that penalty under section 271(1)(c) was not justified and the Tribunal correctly allowed the appeal. On the facts, variations between book sales/gross profit and departmental estimates did not, on the preponderance of probabilities, establish fraud, wilful neglect, or deliberate concealment. The assessee rebutted the statutory presumption in the Explanation to s.271(1)(c), so the Revenue needed independent positive findings of concealment, which were absent. Consequently the imposed penalty of Rs. 92,894 was quashed and decisions answered in favour of the assessee. en-us Wed, 08 Nov 1995 00:00:00 +0530 Wed, 15 Oct 2025 17:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18305 HC held that penalty under section 271(1)(c) was not justified and the Tribunal correctly allowed the appeal. On the facts, variations between book sales/gross profit and departmental estimates did not, on the preponderance of probabilities, establish fraud, wilful neglect, or deliberate concealment. The assessee rebutted the statutory presumption in the Explanation to s.271(1)(c), so the Revenue needed independent positive findings of concealment, which were absent. Consequently the imposed penalty of Rs. 92,894 was quashed and decisions answered in favour of the assessee. Case-Laws Income Tax Wed, 08 Nov 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18305