https://www.taxtmi.com/caselaws?id=466803 Penalty under Section 271(1)(c) was contested where survey records and computerized profit-and-loss accounts showed receipts materially higher than declared; the Assessing Officer recorded satisfaction of concealment after offering opportunities to explain and relied on documentary survey evidence and the assessee's admission of survey figures. Explanation (1) to the penalty provision shifts the evidentiary burden to the assessee once an addition is made and satisfaction of concealment is recorded. The assessee failed to provide a satisfactory explanation for the discrepancy, so the penalty was sustained on those grounds. en-us Wed, 20 Sep 2023 00:00:00 +0530 Thu, 19 Feb 2026 16:38:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466803 Penalty under Section 271(1)(c) was contested where survey records and computerized profit-and-loss accounts showed receipts materially higher than declared; the Assessing Officer recorded satisfaction of concealment after offering opportunities to explain and relied on documentary survey evidence and the assessee's admission of survey figures. Explanation (1) to the penalty provision shifts the evidentiary burden to the assessee once an addition is made and satisfaction of concealment is recorded. The assessee failed to provide a satisfactory explanation for the discrepancy, so the penalty was sustained on those grounds. Case-Laws Income Tax Wed, 20 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466803