1998 (1) TMI 7 - SC ORDER

Interpretation of the Expln. to s. 271(1)(c) - concealed income - it is for the assessee to discharge the onus as contemplated in the said Explanation - in the instant case the onus has not been discharged by assessee - hence High Court was right in concluding that as the difference between the income assessed and the income returned was more than 20 per cent., therefore, the said Explanation became applicable and the ITO was justified in imposing penalty