Dismissing the appeal of the assessee the Court held that the three authorities had concurrently held on the facts against the assessee. There was no proper justification placed by the assessee to consider or to disbelieve that the transaction did not lead to a presumption of concealment of income or suppression of fact, which was covered under S.271(1)(c) and which empowered the assessing authority to levy a penalty. The Tribunal rightly confirmed the levy of penalty. (AY.1996 -97)