The assessee, engaged in real estate and construction, purchased a plot in 1982 for Rs. 25 lakhs and claimed Rs. 26 lakhs towards development. The assessee later revalued the plot at Rs. 1.04 crores and introduced it as capital into a partnership firm (NE). Shortly thereafter the assessee made substantial withdrawals from its capital account. The Assessing Officer treated the withdrawals and the revaluation as arranged events that enabled enjoying benefits without paying tax and brought Rs. 52 lakhs to tax. The Commissioner (Appeals) deleted the addition but the Tribunal restored it and also reinstated the penalty; the assessee’s subsequent references were rejected and certain issues had attained finality by earlier orders. On appeal the court held that on evaluating the materials, the Assessing Officer and Tribunal found that the constitution of the firm and the transactions constituted a device or conduit to evade tax: the assessee inflated asset value, contributed it as capital, and withdrew amounts shortly thereafter. These facts demonstrated suppression of material particulars and timelines, amounting to concealment; the imposition of the minimum prescribed penalty under section 271(1)(c) was justified and did not warrant interference.(AY. 1984-85)