https://www.taxtmi.com/highlights?id=102702 Penalty proceedings for concealment require the Assessing Officer to reach satisfaction during assessment; a later notice cannot replace that jurisdictional requirement. Section 271(1) uses "may", preserving discretion and preventing automatic penalty merely because additional income is declared in returns filed under section 148. The deeming fiction in section 271(1B) applies strictly only where an addition or disallowance is made and the assessment order contains a clear direction to initiate penalty. A statement that proceedings "will be initiated separately" is only a future intention. Explanation 5A may deem concealment in specified circumstances but cannot cure invalid initiation or make penalty automatic. Penalties were deleted, while their merits remained open. en-us Fri, 14 Aug 2026 11:34:54 +0530 Fri, 14 Aug 2026 11:34:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102702 Penalty proceedings for concealment require the Assessing Officer to reach satisfaction during assessment; a later notice cannot replace that jurisdictional requirement. Section 271(1) uses "may", preserving discretion and preventing automatic penalty merely because additional income is declared in returns filed under section 148. The deeming fiction in section 271(1B) applies strictly only where an addition or disallowance is made and the assessment order contains a clear direction to initiate penalty. A statement that proceedings "will be initiated separately" is only a future intention. Explanation 5A may deem concealment in specified circumstances but cannot cure invalid initiation or make penalty automatic. Penalties were deleted, while their merits remained open. Highlights Income Tax Fri, 14 Aug 2026 11:34:54 +0530 https://www.taxtmi.com/highlights?id=102702