Negligence in tax matters isn't automatically suppression of truth or falsehood; penalties require more than mere omission.

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....A mere omission or negligence would not constitute a deliberate act of either suppressio veri or suggestio falsy. By the mere reason of such concealment or of furnishing of inaccurate particulars alone, the assessee does not, ipso facto, become liable to a penalty. Imposition of penalty is not at all automatic. - AT....