https://www.taxtmi.com/caselaws?id=36082 Penalty under the Income-tax Act, 1961 could apply to assessment years ending on or before 31 March 1962 where the assessment was completed on or after 1 April 1962, because penalty proceedings are distinct from assessment proceedings and section 297(2)(g) permits the 1961 Act to govern them. Section 68, however, is confined to assessment: a deeming fiction treating unexplained cash credits as income for assessment cannot, by itself, sustain penalty. In penalty proceedings, the revenue must independently prove concealment or furnishing of inaccurate particulars on the materials placed in that proceeding. en-us Tue, 05 Aug 1980 00:00:00 +0530 Fri, 19 Mar 2010 12:24:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36082 Penalty under the Income-tax Act, 1961 could apply to assessment years ending on or before 31 March 1962 where the assessment was completed on or after 1 April 1962, because penalty proceedings are distinct from assessment proceedings and section 297(2)(g) permits the 1961 Act to govern them. Section 68, however, is confined to assessment: a deeming fiction treating unexplained cash credits as income for assessment cannot, by itself, sustain penalty. In penalty proceedings, the revenue must independently prove concealment or furnishing of inaccurate particulars on the materials placed in that proceeding. Case-Laws Income Tax Tue, 05 Aug 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36082