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“concealment of income”

PenaltySection 271(1)(c)Section 271(1)(c)2,901 judgments

The decision most relied on for concealment of income is CIT v. Manjunatha Cotton & Ginning Factory (359 ITR 565), cited in 2,590 judgments on BharatTax.

Leading authorities on concealment of income

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 248 · 2016 · Supreme Court
953
citing judgments

A notice issued under Section 274 read with Section 271(1)(c) is invalid if it fails to specify whether penalty proceedings are for concealment of particulars of income or furnishing inaccurate particulars of income. Such lack of specificity vitiates the penalty proceedings.

Ashok Pai v. CIT
292 ITR 11 · 2007 · Supreme Court
812
citing judgments

“Concealment of particulars of income” and “furnishing inaccurate particulars of income” are two distinct offences under Section 271(1)(c) of the Income Tax Act. A penalty cannot be levied under one limb if the show cause notice or basis for penalty specifies the other, as this constitutes a complete variance in the reasons for assuming jurisdiction.

CIT v. SSA’s Emerald Meadows
73 Taxmann.com 241 · 2016 · High Court
791
citing judgments

A penalty notice under section 271(1)(c) read with section 274 of the Income Tax Act is invalid if it fails to specify whether the penalty is for concealment of income or for furnishing incorrect particulars of income.

Mr. Mohd. Farhan A. Shaikh v. ACIT
434 ITR 1 · 2021 · High Court
672
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify the exact charge by not striking off the irrelevant limb (concealment of income or furnishing inaccurate particulars of income). Such an omnibus or vague notice renders the penalty proceedings bad in law, and any penalty imposed on its basis is liable to be quashed.

Dilip N. Shroff v. JCIT
291 ITR 519 · 2007 · Supreme Court
565
citing judgments

A penalty notice issued under Section 271(1)(c) is invalid if the Assessing Officer fails to strike out the inapplicable limb (concealment or furnishing inaccurate particulars) from the standard proforma, indicating non-application of mind. The initial burden of proving concealment or inaccurate particulars rests on the Revenue.

CIT v. Kaushalya
216 ITR 660 · 1995 · High Court
511
citing judgments

A penalty levied under Section 271(1)(c) for concealment or furnishing inaccurate particulars of income is not invalidated by the Assessing Officer's failure to strike off irrelevant portions in the show cause notice, provided the assessee understood the exact charge and suffered no prejudice, indicating an application of mind by the AO.

Judgments citing concealment of income

Ketkiben Mineshbhai Shah, Ahmedabad vs. The ITO, Ward-1(2)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 521/AHD/2024[2014-15]Status: DisposedITAT Ahmedabad29 Aug 2024AY 2014-15

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Divatia, A.RFor Respondent: Shri Atul Pandey, Sr. DR
Section 148Section 250Section 271(1)(c)Section 44ASection 69A

added to the total Income of the assessee. Penalty proceeding u/s 271(1)(c) of the IT Act were initiated separately for concealment of income. 4. In appeal before Ld. CIT(Appeals), the assessee submitted that the assessee is a small business owner engaged in the retail trade of clothes

Ram Awatar Dhoot, Kolkata vs. Ward 22(4) Kolkata, Kolkata

In the result, the appeal of the assessee stands allowed

ITA 91/KOL/2024[2015-16]Status: DisposedITAT Kolkata29 Aug 2024AY 2015-16

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.91/Kol/2024 Assessment Year: 2015-16 Ram Awatar Dhoot…...…………….....……………………....………....Appellant 29B, Rabindra Sarani Floor, Room No.10E, Kolkata-700073. [Pan: Adepd7419F] Vs. Ito, Ward-22(4), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Ram Awatar Dhoot, Self, Appeared On Behalf Of The Appellant. Shri P. P. Barman, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 27, 2024 Date Of Pronouncing The Order : August 29, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.12.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Levy/Confirmation Of Penalty U/S 271(1)(C) Of The Act. 3. The Brief Facts Of The Case Are That The Assessee Had Claimed Long- Term Capital Gains On Account Of Sale Of Shares At Rs.14,94,407/-. During The Assessment Proceedings, The Assessee Produced Relevant Documents To Substantiate His Claim, However, The Assessing Officer Held That As Per The Report Received From The Investigation Wing, There

Section 250Section 271(1)(c)

gains. Though the additions have been made/confirmed on the basis of preponderance of probabilities in this case, however, to establish the allegation of concealment of income/ furnishing of inaccurate particulars of income to invoke penal provisions of section 271(1)(c) of the Act, stricter proof is required, which

Sh. Anoop Kumar Gupta, Ajmer vs. ITO, Ward-2(1), Ajmer

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 939/JPR/2024[2014-15]Status: DisposedITAT Jaipur29 Aug 2024AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. P.C. Parwal (C.A.)For Respondent: Smt. Monisha Choudhary (Addl. CIT)
Section 143(3)Section 271(1)(c)Section 274

case, the notice issued u/s 271(1)(c) and the order passed there against without specifying whether the charge is for concealment of income or furnishing inaccurate particulars of income is illegal & bad in law and be quashed.” 3. The brief fact of the case is that assessee filed return ... correctly disclosed all the facts, only because the contention of assessee is not fully accepted, it would not mean that assessee has concealed any income or furnished inaccurate particulars of income. For this purpose, reliance is placed on the following cases:- CIT Vs. Reliance Petroproducts

Lalita Narendra Kothari, Mumbai vs. ITO, Ward 19(3)(1), Mumbai

Appeal is allowed in above terms

ITA 1732/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Aug 2024AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Omkareshwar Chidaraassessment Year: 2014-15

For Appellant: Shri Tanzil Padvekar, A.RFor Respondent: Ms. Dhivya Ruth J., Sr. D.R
Section 143(3)Section 56Section 56(2)Section 56(2)(viib)

initiated on assessee's spouse who Penalty proceedings u/s for furnishing wrong particulars of income and for concealment of income.” 6. It is thus clear that both the learned lower authorities have made the impugned addition on “protective” basis without framing any substantive assessment to this clinching effect

Borgwarner Emissions Systems India Private Limited, New Delhi vs. DCIT, Circle-4(2), Delhi

Appeal is allowed

ITA 2015/DEL/2022[2013-14]Status: DisposedITAT Delhi29 Aug 2024AY 2013-14

Bench: Shri Pradip Kumar Kedia & Shri Narinder Kumar

For Appellant: Shri Rohit Tiwari, AdvocateFor Respondent: Shri Rajesh Kumar, CIT(DR)
Section 143(3)Section 234BSection 271(1)(c)Section 92C

came to be added to the total income of the assessee, in addition to directions for initiation of penalty proceedings because of concealment of income by the assessee. Income tax demand of Rs. 4,64,10,920, including amount of interest under section 234B and 234C has been raised against

Pramod Kumar Saraf, Kolkata vs. ITO, Ward-22(2), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 683/KOL/2024[2014-15]Status: DisposedITAT Kolkata28 Aug 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. No.683/Kol/2024 Assessment Year: 2014-15 Pramod Kumar Saraf...…………….....……………………....………....Appellant 24, R. N Mukherjee Road, Mission Row, Kol-1. [Pan: Apkps6814F] Vs. Ito, Ward-22(2), Kolkata…...................................................…..…..... Respondent Appearances By: Shri Sunil Surana, Ar, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit- Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : June 26, 2024 Date Of Pronouncing The Order : August 28, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.03.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Agitated Against The Levy/Confirmation Of Penalty U/S 271(1)(C) Of The Act. 3. The Brief Facts Of The Case Are That The Assessee Had Claimed Long- Term Capital Gains On Account Of Sale Of Shares At Rs.7,10,447/-. During The Assessment Proceedings, The Assessee Produced Relevant Documents To Substantiate His Claim, However, The Assessing Officer Held That As Per The Report Received From The Investigation Wing, There Was Large Scale Price Rigging Of Certain Scrips, Whereby, The Bogus Long-Term

Section 250Section 271(1)(c)

gains. Though the additions have been made/confirmed on the basis of preponderance of probabilities in this case, however, to establish the allegation of concealment of income/ furnishing of inaccurate particulars of income to invoke penal provisions of section 271(1)(c) of the Act, stricter proof is required, which

Svm Cera Private Limited, Gujrat vs. ACIT, C.C-1(1). Kolkata., Kolkata

In the result, both the appeals in ITA Nos

ITA 974/KOL/2023[2015-16]Status: DisposedITAT Kolkata28 Aug 2024AY 2015-16

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri P.K. Sanghai, ARFor Respondent: Shri Ankur Goyal, DR
Section 132Section 132(4)Section 143(3)Section 153ASection 271(1)(c)

undisputed fact that, the no incriminating documents were found during the course of search to prove the concealment of income and the penalty was imposed merely on the basis of income surrendered by the appellant in his statement and shown in the ITR filed u/s 153A

Svm Cera Private Limited, Gujrat vs. ACIT, C.C-1(1), Kolkata

In the result, both the appeals in ITA Nos

ITA 973/KOL/2023[2014-15]Status: DisposedITAT Kolkata28 Aug 2024AY 2014-15

Bench: Shri Rajpal Yadav, Vp & Shri Dr. Manish Borad, Am

For Appellant: Shri P.K. Sanghai, ARFor Respondent: Shri Ankur Goyal, DR
Section 132Section 132(4)Section 143(3)Section 153ASection 271(1)(c)

undisputed fact that, the no incriminating documents were found during the course of search to prove the concealment of income and the penalty was imposed merely on the basis of income surrendered by the appellant in his statement and shown in the ITR filed u/s 153A

Mumbai Police Wefare Fund, Mumbai vs. Assistant Commissioner of Income Tax-17(2), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 1219/MUM/2024[2014-15]Status: DisposedITAT Mumbai28 Aug 2024AY 2014-15

Bench: Shri Anikesh Banerjeeand Shri Girish Agrawal

For Appellant: Shri Rajiv KhandelwalFor Respondent: ShriP.D.Chougule(Addl.CIT) SR DR
Section 147Section 148Section 250Section 271Section 271(1)(c)

recorded reason and the tax was paid in full. In the assessment ld. AOaccepted ROI and tax paid and no other findings for concealment of income was found. The assessee is a welfare fund and not in the activity of profit making. All the personnel are employed in the State

Data Ingenious Global Limited, Alwar vs. ACIT, Central Circle, Alwar

ITA 652/JPR/2024[2011-12]Status: DisposedITAT Jaipur27 Aug 2024AY 2011-12
Section 139(1)Section 143(3)Section 153ASection 271(1)

ITA NO. 652/JP/2024 DATA INGENIOUS GLOBAL LTD. VS ACIT, CENTRAL CIRCLE, ALWAR Nalwa Sons Investment Limited dated 26.08.2010 ITAno. 1420/2009

Rajiv Pratap Joshi, Thane vs. Income Tax Officer, Ward 3(1)-Kalyan, Thane

In the result, the appeal by the assessee is allowed for statistical purposes

ITA 3329/MUM/2024[2014-2015]Status: DisposedITAT Mumbai27 Aug 2024AY 2014-2015

Bench: Shri Narendra Kumar Billaiya & Shri Sandeep Singh Karhail

For Appellant: NoneFor Respondent: Smt. Mahita Nair, Sr. DR
Section 148Section 250Section 271(1)(c)Section 271F

Learned CIT(A)/NFAC erred in confirming order of Assessing Officer levying penalty u/s 271(1)(c) of Rs. 4,42,588/- for concealment of income of Rs. 21,11,601/- being the entire income disclosed in the return of income filed pursuant to notice u/s 148 on the ground ... that original return of income was not filed without appreciating that there is no concealment of income as there is no tax evasion as there is refund post assessment due to TDS being more than tax liability and no addition or disallowance is made in the assessment and the returned

Stillwater Defence Textile Technologies, Mumbai vs. ACIT, Circle-1(3)(1), Mumbai

ITA 1249/MUM/2024[2014-15]Status: DisposedITAT Mumbai27 Aug 2024AY 2014-15

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Swapnil NewaskarFor Respondent: Shri Avinash Baburao Karpe
Section 143(3)Section 271Section 271(1)Section 271(1)(c)

facts and circumstances the learned ACIT has erred in levy u/s. 271 (1) (c). Such penalty can be levied only in case of concealment of income and furnishing inaccurate details. In our case, there was no intentional concealment of income and furnishing inaccurate details In our case there ... intentional concealment of income. It was a bonafide error and so penalty cannot be levied on it. 2. Order of Fresh Assessment is still pending, the previous orders passed by the Ld. A.O. dated 29/12/2016 for assessment and impugned Penalty order dated 29/03/2019 issued pursuant to old assessment order stands

ACIT, Circle-4(2), New Delhi vs. Boranda International Pvt. Ltd., Delhi

In the result, the appeal of the Revenue in ITA No

ITA 2019/DEL/2021[2016-17]Status: DisposedITAT Delhi27 Aug 2024AY 2016-17

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Sushil Chadha, ARFor Respondent: Shri Kanv Bali, Sr. DR
Section 271(1)(c)Section 37(1)

added the same to the income of the assessee. Penalty proceedings u/s 271(1)(c) of the Act was separately initiated for concealment of income. The AO also disallowed an amount of Rs 47,05,802/- u/s 37(1) of the Act. 6. Aggrieved, the assessee went in appeal before

Fabrikant Trading (India) Private Limited, Mumbai vs. DCIT Circle 5(1)(1), Mumbai

In the result, the appeal by the assessee is allowed

ITA 474/MUM/2024[2007-08]Status: DisposedITAT Mumbai26 Aug 2024AY 2007-08

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Rashmikant Modi/Ms. KetkiFor Respondent: Ms Usha Gaikwad, Sr. AR
Section 143(3)Section 250Section 271(1)(c)Section 274Section 69C

section 271(1)(c) of the Act submitted that the AO has not specified whether the penalty has been levied for concealment of income or for furnishing inaccurate particulars of income. The learned AR in support of his submission relied on various decisions of the coordinate bench of the Tribunal ... Taxmann.com 449 (Cal.) to support the contention that when the AO has recorded in the assessment order particulars of concealed income/undisclosed income of the assessee and on that basis initiated penalty proceedings under section 271(1)(c) of the Act then consequential notice under section 274 issued

Satish Garg, Yamuna Nagar vs. Income Tax Officer, Ward-4, Income Tax Office, Yamuna Nagar

In the result, the appeal of the Assessee stands allowed

ITA 254/CHANDI/2024[2016-17]Status: DisposedITAT Chandigarh23 Aug 2024AY 2016-17

Bench: Shri Sanjay Garg & Shri Krinwant Sahayआयकर अपील सं./Ita No 254/Chd/2024 "नधा"रण वष" / Assessment Year : 2016-17 Satish Garg, Vs The Ito, 23, Madhu Colony, Ward-4, Yamunanagar Income Tax Office, Yamunanagar "थायीलेखासं./Pan No: Aawpk7566K अपीलाथ"/Appellant ""यथ"/Respondent

For Appellant: Shri Dhruv Goel, CAFor Respondent: Shri Vivek Vardhan, JCIT, Sr.DR
Section 271

impugned penalty order dated 28.06.2016 to submit that, in fact, there was no intentional furnishing of inaccurate particulars of income or concealment of income in this case. The ld. counsel submitted that the Assessee during the year had received interest income from two firms. The amount ... Assessee. The ld. Counsel, therefore, has submitted that this is not a case of intentional furnishing of inaccurate particulars of income or concealment of income. The aforesaid discrepancy occurred only due to the clerical error. The ld. Counsel, in this respect, has relied on the decision

Babubhai Punmaji Gehlot, Ahmedabad vs. The ITO, Ward-5(3)(3), Ahmedabad

The appeals of the assessee are allowed for statistical purposes

ITA 1034/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad23 Aug 2024AY 2007-08

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

For Appellant: Shri Nimesh Vayawala, A.RFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 143(3)Section 271(1)Section 271(1)(C)Section 271(1)(c)Section 44A

total income of the assessee. The Assessing Officer also initiated penalty proceedings under Section 271(1)(c) of the Act for concealment of income. The said assessment order was passed on 31.12.2009. 5. The assessee filed appeal against aforesaid assessment order of Ld. Assessing Officer on 05.01.2017, after

Babubhai Punmaji Gehlot, Ahmedabad vs. The ITO, Ward-5(3)(3), Ahmedabad

The appeals of the assessee are allowed for statistical purposes

ITA 1033/AHD/2019[2007-08]Status: DisposedITAT Ahmedabad23 Aug 2024AY 2007-08

Bench: Shri Ramit Kochar & Shri Siddhartha Nautiyal

For Appellant: Shri Nimesh Vayawala, A.RFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 143(3)Section 271(1)Section 271(1)(C)Section 271(1)(c)Section 44A

total income of the assessee. The Assessing Officer also initiated penalty proceedings under Section 271(1)(c) of the Act for concealment of income. The said assessment order was passed on 31.12.2009. 5. The assessee filed appeal against aforesaid assessment order of Ld. Assessing Officer on 05.01.2017, after

Deputy Commissioner of Income Tax, Chennai vs. S. Deepalakshmi, Panruti

In the result, the appeal filed by the Revenue is dismissed

ITA 991/CHNY/2024[2016-17]Status: DisposedITAT Chennai23 Aug 2024AY 2016-17

Bench: Shri Mahavir Singhand Shri S.R. Raghunathaआयकर अपील सं./Ita No.:991/Chny/2024 "नधा"रण वष"/Assessment Year:2016-17 The Deputy Commissioner Of Ms. S. Deepalakshmi, Income Tax, Vs. No.190, Annai Indira Gandhi Central Circle -2(2), Salai, Chennai. Panruti – 607 108. Pan: Awtpd 8317Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Smt. R. Anita, Addl. Cit ""यथ"क" ओर से/Respondent By : None सुनवाई क" तार"ख/Date Of Hearing : 20.08.2024 घोषणा क" तार"ख/Date Of Pronouncement : 23.08.2024 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Revenue Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeal), Chennai - 19 Dated 13.02.2024. The Assessment Was Framed By The Deputy Commissioner Of Income Tax, Cuddalore Circle, Cuddalore For The Assessment Year 2016-17 U/S.143(3) R.W.S. 147 Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Order Dated 31.12.2018. 2. The Sole Issue In This Appeal Of Revenue Is As Regards To The Order Of Cit(A) Deleting The Penalty Levied By Ao U/S.271(1)(C) Of The Act Amounting To Rs.51,18,200/- For The Reason That There Is No Specific Charge Framed While Initiating Penalty U/S.271(1)(C) Of The Act I.E., Whether Assessee Has Concealed The Particulars Of Income Or Furnishing Inaccurate Particulars Of Income.

For Appellant: Smt. R. Anita, Addl. CITFor Respondent: None
Section 143(3)Section 148Section 271(1)Section 271(1)(c)Section 274Section 40

penalty proceedings u/s.271(1)(c) of the Act and levied penalty of Rs.51,80,200/- being 100% of the tax on the alleged concealed trading income. Aggrieved, assessee preferred appeal before CIT(A). 4. Before CIT(A), the assessee made submission that the levy of penalty is invalid ... specified in the notice whether the penalty is levied for concealment of income or for furnishing inaccurate particulars. He further contended that the AO has not struck of the inapplicable words in the notice u/s.274 r.w.s. 271 of the Act and therefore, the notice and the entire proceedings are invalid

Tej Organisers Pvt.Ltd., Ahmedabad vs. Income Tax Officer, Ward-4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 50/AHD/2022[2012-13]Status: DisposedITAT Ahmedabad22 Aug 2024AY 2012-13

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Biren Shah & Shri Gulab Thakor, A.RsFor Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 271(1)(c)Section 274

added to the total income as unexplained investment. Penalty proceedings under section 274 read with section 271(1)(c) were initiated separately for concealment of income. 4. In appeal, Ld. CIT(Appeals) observed that the AO noted a discrepancy between the closing balance of a loan advance to Shri Kanaiyo

ACIT-2(3)(1)Q, Mumbai vs. N R Agarwal Industries, Mumbai

In the result, appeals of the revenue are dismissed

ITA 3460/MUM/2024[2012-13]Status: DisposedITAT Mumbai22 Aug 2024AY 2012-13

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 14ASection 271(1)(c)Section 801ASection 80I

this case, the AO had levied penalty u/s 271(1)(c) for concealment of income on the following additions made in case of appellant:- Sr. Particulars Amount (in Rs.) No (i) Enhancement made by 4,15,89,737 CIT(A) in Unit-II and Unit-III (ii) Disallowance u/s 80IA ... Assessing Officer had correctly reached the conclusion that since the assessee had claimed excessive deductions knowing that they are incorrect; it amounted to concealment of income. It was tried to be argued that the falsehood in accounts can take either of the two forms; (i) an item of receipt