https://www.taxtmi.com/caselaws?id=39401 Penalty under section 28(1)(c) could not be sustained where the assessed addition arose from the assessee's stock explanation and did not amount to a clear admission of concealment. The court held that an addition in assessment is not, by itself, conclusive proof of deliberate concealment or contumacious conduct. Because part of the explanation was accepted and only part of the stock remained unexplained, the revenue failed to establish the culpable element required for penalty. The answer to the referred question was therefore in the negative, and the assessee was held not liable to penalty on the facts proved. en-us Thu, 08 Aug 1974 00:00:00 +0530 Fri, 16 Apr 2010 12:28:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39401 Penalty under section 28(1)(c) could not be sustained where the assessed addition arose from the assessee's stock explanation and did not amount to a clear admission of concealment. The court held that an addition in assessment is not, by itself, conclusive proof of deliberate concealment or contumacious conduct. Because part of the explanation was accepted and only part of the stock remained unexplained, the revenue failed to establish the culpable element required for penalty. The answer to the referred question was therefore in the negative, and the assessee was held not liable to penalty on the facts proved. Case-Laws Income Tax Thu, 08 Aug 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39401