Held that there was no evidence suggesting that the explanation offered by the assessee was false. Thus the claim of the assessee could not be said to amount to concealment of particulars of income. Likewise, there was no finding of the authorities below qua the fact that the assessee failed to substantiate the explanation offered by him and failed to prove that such explanation was bona fide with respect to material facts relating to the computation of total income. Thus the provisions of Explanation 1 to section 271(1)(c) of the Act were not attracted. Order levying penalty was set aside. (AY.2013-14)