https://www.taxtmi.com/caselaws?id=755121 Penalty under section 271(1)(c) was held unsustainable where the seized material and accompanying statement did not clearly establish the financial year or assessment year in which the alleged cash payment was made. Although the quantum addition had been sustained and the papers could still support an addition under section 69B, the ambiguity on year-wise attribution prevented penal liability from being fastened. The decision treats penalty proceedings as independent from assessment proceedings and requires clear evidence of concealment for the relevant year before concealment penalty can be imposed. en-us Wed, 03 Jul 2024 00:00:00 +0530 Sat, 06 Jul 2024 07:52:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755121 Penalty under section 271(1)(c) was held unsustainable where the seized material and accompanying statement did not clearly establish the financial year or assessment year in which the alleged cash payment was made. Although the quantum addition had been sustained and the papers could still support an addition under section 69B, the ambiguity on year-wise attribution prevented penal liability from being fastened. The decision treats penalty proceedings as independent from assessment proceedings and requires clear evidence of concealment for the relevant year before concealment penalty can be imposed. Case-Laws Income Tax Wed, 03 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755121