https://www.taxtmi.com/caselaws?id=55710 Sales routed through sister concerns at below-market prices, with direct delivery to outside purchasers and only book-entry activity by the intermediaries, were treated as sham transactions used to divert profits and conceal income. On those facts, concealment penalty under section 271(1)(c) was considered attracted, with concealment and furnishing inaccurate particulars treated as overlapping in the case. Explanation 1 to section 271(1)(c) was described as a rebuttable rule of evidence that can be invoked at the appellate stage even if not expressly relied on by the Assessing Officer. The taxpayer failed to rebut the presumption, and the double-taxation objection was rejected. The penalty was sustained, subject to reduction to the minimum quantum. en-us Fri, 06 Aug 1999 00:00:00 +0530 Mon, 29 Nov 2010 15:49:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=55710 Sales routed through sister concerns at below-market prices, with direct delivery to outside purchasers and only book-entry activity by the intermediaries, were treated as sham transactions used to divert profits and conceal income. On those facts, concealment penalty under section 271(1)(c) was considered attracted, with concealment and furnishing inaccurate particulars treated as overlapping in the case. Explanation 1 to section 271(1)(c) was described as a rebuttable rule of evidence that can be invoked at the appellate stage even if not expressly relied on by the Assessing Officer. The taxpayer failed to rebut the presumption, and the double-taxation objection was rejected. The penalty was sustained, subject to reduction to the minimum quantum. Case-Laws Income Tax Fri, 06 Aug 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=55710