https://www.taxtmi.com/caselaws?id=20856 HC held that where the Tribunal found no concealment of income, the foundational basis for a notice under s.271(1)(c) and for levying penalty under the Explanation to s.271(1)(c) ceased to exist. Penalty proceedings under the Explanation must be strictly initiated and the assessee must be given an opportunity to meet that case; absent such initiation and opportunity, levy of penalty was unsustainable. The court allowed the assessee's appeal and answered the referred question in the assessee's favour. en-us Mon, 09 Nov 1992 00:00:00 +0530 Fri, 24 Oct 2025 11:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20856 HC held that where the Tribunal found no concealment of income, the foundational basis for a notice under s.271(1)(c) and for levying penalty under the Explanation to s.271(1)(c) ceased to exist. Penalty proceedings under the Explanation must be strictly initiated and the assessee must be given an opportunity to meet that case; absent such initiation and opportunity, levy of penalty was unsustainable. The court allowed the assessee's appeal and answered the referred question in the assessee's favour. Case-Laws Income Tax Mon, 09 Nov 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20856