https://www.taxtmi.com/caselaws?id=28943 Penalty under section 271(1)(c) requires the Revenue to prove that the amount represented income of the relevant year and that the assessee consciously concealed income or furnished inaccurate particulars. An assessment finding may be relevant, but it is not conclusive for penalty. Here, the disclosure petition surrendering peak hundi credits and asking for spread-over treatment did not amount to a clear admission that the sum was the assessee's income for the year in question. A mere offer of the amount for taxation, without cogent material showing a revenue receipt in that year, was insufficient to sustain penalty. en-us Tue, 18 Aug 1981 00:00:00 +0530 Mon, 08 Mar 2010 17:33:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28943 Penalty under section 271(1)(c) requires the Revenue to prove that the amount represented income of the relevant year and that the assessee consciously concealed income or furnished inaccurate particulars. An assessment finding may be relevant, but it is not conclusive for penalty. Here, the disclosure petition surrendering peak hundi credits and asking for spread-over treatment did not amount to a clear admission that the sum was the assessee's income for the year in question. A mere offer of the amount for taxation, without cogent material showing a revenue receipt in that year, was insufficient to sustain penalty. Case-Laws Income Tax Tue, 18 Aug 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28943