https://www.taxtmi.com/caselaws?id=57860 The Tribunal upheld penalties imposed under section 271(1)(c) for concealment of income by a private limited company. The CIT(A)'s invocation of Explanation 1 to section 271(1)(c) was deemed invalid as it was not raised by the Assessing Officer. The burden of proving mens rea in penalty proceedings was placed on the revenue, and the Tribunal found the assessee's lack of disclosure constituted concealment. The penalties imposed by the AO and confirmed by the CIT(A) were upheld for both assessment years. en-us Fri, 14 Oct 1994 00:00:00 +0530 Wed, 15 Dec 2010 10:32:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57860 The Tribunal upheld penalties imposed under section 271(1)(c) for concealment of income by a private limited company. The CIT(A)'s invocation of Explanation 1 to section 271(1)(c) was deemed invalid as it was not raised by the Assessing Officer. The burden of proving mens rea in penalty proceedings was placed on the revenue, and the Tribunal found the assessee's lack of disclosure constituted concealment. The penalties imposed by the AO and confirmed by the CIT(A) were upheld for both assessment years. Case-Laws Income Tax Fri, 14 Oct 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57860