Meaning of Concealment

Normally that though the word ‘ deliberate’ had been omitted by the Finance Act, 1964 from the language of section 271(1) (c), yet the word ‘ conceal’ implies hide or withdraw from observation, to cover or keep away from sight, to prevent the discovery of, to withdraw knowledge of. It is thus implicit in the word ‘ concealed’ that there has been a deliberate act on the part of the assessee. Following this basis the bench held that opinion and discretion exercised under section 40A(2) in the quantum of expenses thus cannot lead to the concealment of income especially so when the assessee is an export oriented undertaking not liable to tax either.

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