Held that since the assessee neither filed its return of income under s. 139 nor filed the return in response to notice issued under S. 148 despite the fact that it received substantial contract receipts during the relevant year, the case c falls in the category of “concealment of particulars of income” for the purpose of S. 271(1)(c) r/w Expln. 3 thereto and, therefore, the levy of penalty is justified, even though the addition has been made by applying the net profit rate. (AY. 2011-12)