https://www.taxtmi.com/caselaws?id=24266 Penalty for concealment under section 271(1)(c) cannot be initiated on the basis of a merely protective assessment, because concealment must first be established through a substantive assessment of concealed income in the assessee's hands. Where the Revenue has only made a protective addition and the income remains linked to another person for assessment purposes, no valid penalty can be fastened on the assessee. The cancellation of penalty was therefore upheld in favour of the assessee. en-us Wed, 21 Dec 1988 00:00:00 +0530 Mon, 18 Jan 2010 18:23:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24266 Penalty for concealment under section 271(1)(c) cannot be initiated on the basis of a merely protective assessment, because concealment must first be established through a substantive assessment of concealed income in the assessee's hands. Where the Revenue has only made a protective addition and the income remains linked to another person for assessment purposes, no valid penalty can be fastened on the assessee. The cancellation of penalty was therefore upheld in favour of the assessee. Case-Laws Income Tax Wed, 21 Dec 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24266