https://www.taxtmi.com/caselaws?id=285275 Penalty proceedings under section 28(1)(c) of the Income-tax Act, 1922 are penal in character, so the revenue must prove concealment or deliberate furnishing of inaccurate particulars. A mere difference between the assessee's returned estimate and the income later assessed does not, by itself, justify an inference of dishonesty or falsehood. Because the penalty order treated that disparity as evidence of concealment, it contained an error of law on the face of the record. As the extent to which that error affected the decision could not be determined, the penalty order was quashed. en-us Sat, 04 Mar 1961 00:00:00 +0530 Mon, 06 Jan 2020 14:18:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=285275 Penalty proceedings under section 28(1)(c) of the Income-tax Act, 1922 are penal in character, so the revenue must prove concealment or deliberate furnishing of inaccurate particulars. A mere difference between the assessee's returned estimate and the income later assessed does not, by itself, justify an inference of dishonesty or falsehood. Because the penalty order treated that disparity as evidence of concealment, it contained an error of law on the face of the record. As the extent to which that error affected the decision could not be determined, the penalty order was quashed. Case-Laws Income Tax Sat, 04 Mar 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=285275