MAK DATA P. LTD. vs COMMISSIONER OF INCOME TAX-II

The Supreme Court held that the imposition of penalty under Section 271(1)(c) of the Income Tax Act requires the Assessing Officer to record satisfaction regarding concealment of income. The Court found that the assessee's voluntary surrender of income was conditional and did not imply admission of concealment. Consequently, the penalty of Rs.14,61,547/- was set aside, affirming the Income Tax Appellate Tribunal's decision to allow the appeal based on the lack of evidence for concealment.