https://www.taxtmi.com/caselaws?id=799601 Penalty under Section 271(1)(c) requires clear identification and proof of either concealment of income particulars or furnishing inaccurate particulars, which are distinct defaults. Inaccurate particulars concern incorrect, erroneous or false details in a return, whereas non-disclosure falls within concealment. Where a penalty order invokes both defaults without conclusively identifying either, and Explanation 1 does not apply because the taxpayer's explanation was neither found false nor rejected and formed the basis of the addition, statutory conditions remain unmet. The civil nature of the penalty dispenses with mens rea but does not make penalty automatic upon an addition. en-us Mon, 31 Aug 2026 00:00:00 +0530 Thu, 24 Sep 2026 08:27:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799601 Penalty under Section 271(1)(c) requires clear identification and proof of either concealment of income particulars or furnishing inaccurate particulars, which are distinct defaults. Inaccurate particulars concern incorrect, erroneous or false details in a return, whereas non-disclosure falls within concealment. Where a penalty order invokes both defaults without conclusively identifying either, and Explanation 1 does not apply because the taxpayer's explanation was neither found false nor rejected and formed the basis of the addition, statutory conditions remain unmet. The civil nature of the penalty dispenses with mens rea but does not make penalty automatic upon an addition. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799601