Section 271(1)(c) can be invoked only if there is a "concealment of particulars of income"

RELEVANT PARAGRAPH

20. It seems to us that the revenue functions in the same manner as other departments of administration, wherein the accepted norm is, to shift the responsibility of decision making to the judiciary. In sum and substance, the judiciary not only adjudicates upon legitimate controversies between quarreling parties, but also discharges the executive function of decision making. In furtherance of the intention expressed by this Court the revenue

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