https://www.taxtmi.com/caselaws?id=789266 Penalty under section 271(1)(c) in a search assessment is tested against the return filed in response to section 153A, which operates as the relevant return for concealment analysis. Where the income disclosed in that return is accepted in assessment and no incriminating material shows concealment or inaccurate particulars, penalty is not warranted on the surrendered income. Penalty is also not sustained on additions made only on estimate or from calculation errors, because such items do not by themselves establish the requisite concealment. The result is that concealment-based penalty fails where the assessed variation is unsupported by incriminating material or is merely arithmetical or estimated in nature. en-us Wed, 25 Mar 2026 00:00:00 +0530 Mon, 06 Apr 2026 08:51:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789266 Penalty under section 271(1)(c) in a search assessment is tested against the return filed in response to section 153A, which operates as the relevant return for concealment analysis. Where the income disclosed in that return is accepted in assessment and no incriminating material shows concealment or inaccurate particulars, penalty is not warranted on the surrendered income. Penalty is also not sustained on additions made only on estimate or from calculation errors, because such items do not by themselves establish the requisite concealment. The result is that concealment-based penalty fails where the assessed variation is unsupported by incriminating material or is merely arithmetical or estimated in nature. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789266