https://www.taxtmi.com/caselaws?id=25473 The text addresses penalty liability under section 271(1)(c), focusing on the Explanation that operates when returned income is under eighty per cent., which raises rebuttable presumptions and shifts the initial burden to the assessee to prove absence of fraud or gross or willful neglect; consequence: authorities must determine whether the assessee discharged that burden. It further states that penalty proceedings are quasi-criminal and require independent adjudicationassessment findings have probative value but are not conclusive; consequence: reliance solely on quantum findings to impose penalty is legally defective and necessitates remand for fresh penalty adjudication. en-us Mon, 14 Sep 1987 00:00:00 +0530 Thu, 15 Jan 2026 17:55:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25473 The text addresses penalty liability under section 271(1)(c), focusing on the Explanation that operates when returned income is under eighty per cent., which raises rebuttable presumptions and shifts the initial burden to the assessee to prove absence of fraud or gross or willful neglect; consequence: authorities must determine whether the assessee discharged that burden. It further states that penalty proceedings are quasi-criminal and require independent adjudicationassessment findings have probative value but are not conclusive; consequence: reliance solely on quantum findings to impose penalty is legally defective and necessitates remand for fresh penalty adjudication. Case-Laws Income Tax Mon, 14 Sep 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25473