https://www.taxtmi.com/caselaws?id=18756 The High Court declined to answer the reference as there was no intentional concealment of income by the assessee. The Tribunal's detailed analysis found that the revised return was filed after informing the Income-tax Officer about the figures subject to settlement, indicating no wilful concealment. The Tribunal emphasized that penalty proceedings require conscious concealment, which was not established. The settlement agreement was viewed as a means to settle disputes, not an admission of concealment. The burden of proof to establish concealment was held to be on the Revenue, and the Tribunal's factual findings were conclusive, leading to no legal question for court reference. en-us Tue, 21 Feb 1995 00:00:00 +0530 Sat, 31 Oct 2009 17:59:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18756 The High Court declined to answer the reference as there was no intentional concealment of income by the assessee. The Tribunal's detailed analysis found that the revised return was filed after informing the Income-tax Officer about the figures subject to settlement, indicating no wilful concealment. The Tribunal emphasized that penalty proceedings require conscious concealment, which was not established. The settlement agreement was viewed as a means to settle disputes, not an admission of concealment. The burden of proof to establish concealment was held to be on the Revenue, and the Tribunal's factual findings were conclusive, leading to no legal question for court reference. Case-Laws Income Tax Tue, 21 Feb 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18756