https://www.taxtmi.com/caselaws?id=39566 Penalty proceedings for concealment are independent of assessment, so an estimate used in assessment is only evidentiary and not conclusive. Where the assessee disputes the basic figure said to have been concealed, the authority must verify that figure on the materials available in the penalty proceedings; without a clear finding on the correctness of the estimated cost of construction, the concealment penalty cannot rest on a complete foundation. The applicable penalty statute under the transition provisions depends on the date of completion of assessment: the 1961 Act applies where assessment was completed after 1 April 1962, while the 1922 Act applies where assessment was completed earlier. The penalty provisions were upheld as valid on that basis. en-us Fri, 14 Mar 1975 00:00:00 +0530 Sat, 17 Apr 2010 12:48:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39566 Penalty proceedings for concealment are independent of assessment, so an estimate used in assessment is only evidentiary and not conclusive. Where the assessee disputes the basic figure said to have been concealed, the authority must verify that figure on the materials available in the penalty proceedings; without a clear finding on the correctness of the estimated cost of construction, the concealment penalty cannot rest on a complete foundation. The applicable penalty statute under the transition provisions depends on the date of completion of assessment: the 1961 Act applies where assessment was completed after 1 April 1962, while the 1922 Act applies where assessment was completed earlier. The penalty provisions were upheld as valid on that basis. Case-Laws Income Tax Fri, 14 Mar 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39566