https://www.taxtmi.com/caselaws?id=39095 Imposition of penalty for concealment under income tax law was examined with focus on the Explanation shifting the evidential burden to the assessee; the Explanation requires recomputation of income by reducing amounts disallowed from claimed deductions when assessing penalty quantum, and thus affects applicability and retrospective operation. The tribunal did not consider the Explanation and no recomputation was made; absence of findings prevented determination of retrospectivity. Given these considerations the appellate question was answered in favour of the assessee on the material before the court. en-us Fri, 15 Sep 1972 00:00:00 +0530 Thu, 15 Jan 2026 10:41:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39095 Imposition of penalty for concealment under income tax law was examined with focus on the Explanation shifting the evidential burden to the assessee; the Explanation requires recomputation of income by reducing amounts disallowed from claimed deductions when assessing penalty quantum, and thus affects applicability and retrospective operation. The tribunal did not consider the Explanation and no recomputation was made; absence of findings prevented determination of retrospectivity. Given these considerations the appellate question was answered in favour of the assessee on the material before the court. Case-Laws Income Tax Fri, 15 Sep 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39095