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Issues Involved: Assessment of penalty u/s 271(1)(c) of the Income-tax Act, 1961 based on alleged concealment of income or furnishing inaccurate particulars.
Summary: The case involved an individual assessee who filed his return of income for the assessment year 1961-62, showing a total income of Rs. 86,029, with a withdrawal of Rs. 2,000 for household expenses. The Income-tax Officer estimated higher household expenses at Rs. 6,000, adding Rs. 4,000 to the income for assessment. Subsequent appeals and rectification applications were dismissed, leading to a penalty of Rs. 6,061 imposed by the Inspecting Assistant Commissioner u/s 271(1)(c) read with section 274(2) of the Act. The Tribunal upheld the penalty, prompting the assessee to move the High Court for reference of questions of law. The main contention was whether there was sufficient evidence to conclude that the assessee had concealed income or furnished inaccurate particulars for the penalty. The High Court found that the evidence presented, including the lifestyle and income sources of the assessee, supported the conclusion of concealment. The Court referenced precedents emphasizing the need for circumstances to point to conscious concealment or deliberate furnishing of inaccurate particulars before imposing penalties. The Court observed that the assessee's claim of minimal household expenses was unreasonable given his substantial income and family size. The Court highlighted discrepancies in the explanations provided by the assessee, indicating a deliberate attempt to conceal income. The judgment emphasized the societal impact of such concealment on the economy and upheld the penalty, ruling in favor of the revenue and against the assessee. In conclusion, the High Court affirmed the penalty imposed u/s 271(1)(c) of the Income-tax Act, 1961, based on the evidence indicating concealment of income or furnishing of inaccurate particulars by the assessee.
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