Held that the record showed that the additions were made on the basis of the clear documentary evidence found during the Income-tax survey proceedings against the assessee. The material on record showed that the Assessing Officer had provided a reasonable opportunity to the assessee and also sought clarification, and having not been satisfied with the explanation provided by the assessee, the Assessing Officer had passed the order and recorded the reasons for his conclusion that there had been concealment of income. The levy of penalty was valid.(AY. 1998-99)