This is case of imposition of penalty for concealment of income. 2. assessee disclosed certain additional income in revised return saying that this was in order to buy peace and in very next assessment year this additional sum was found credited in accounts of partners. It is for this reason that Income-tax Officer invoking provisions of Explanation 2 to section 271(1) (c) imposed penalty. CIT (Appeals) has sustained it. Therefore, assessee is in appeal. 3. For sake of completeness facts are stated in greater detail as follows: assessee filed its return on 28-4-1984 disclosing income of Rs. 2,74,510. Income-tax Officer wrote to assessee asking it to attend on 4- 9-1984 and to file copies of accounts of certain creditors and again on 26-9-1984 Income-tax Officer wrote to assessee pointing out credits totalling to Rs. 3,30,000 and asking assessee to furnish evidence to prove source of said credits from concerned parties. assessee replied on 6-10-1984 stating that purchases from M/s P. K. Padmanabhan & Sons were genuine. Income-tax Officer wrote another letter dated 27-10-1984 regarding source of above credits. Thereafter, on 19-11-1984 Income-tax Officer wrote another letter proposing to treat aforesaid credits as income of assessee under section 68. Income-tax Officer also informed assessee that he had issued summons to one of creditors at address given by assessee and same had been returned unserved. assessee filed letter dated 21-12-1984 where in, inter alia, it stated as follows: "There are certain cash credits in accounts of certain persons and full address of loan creditors was furnished to you. Confirmatory letters were also filed for such loans. In order to purchase peace, we are offering round sum of Rs. 2,50,000 to income already returned and we request you to complete assessment as per revised return filed." assessee then filed return dated 28-12- 1984. Subsequently, in course of assessment for assessment year 1984-85 income-t ax Officer found, as stated above in brief statement, that accounts of partners were credited with total sum of Rs. 2,50,000 in proportion to their profit sharing ratio along with narration that these credits represented additional income offered for assessment in assessment year 1983-84. assessee in its letter to Income-tax Officer dated 21-12-1985, inter alia, stated as follows: "We have specifically stated that credits relate to income offered for 1983-84 assessment, which income was returned by us and accepted by ITO." assessee filed reply dated 12-2-1986 to Income-tax Officer's notice under section 274 read with section 271, but it filed no reply to Income-tax Officer's letter dated 18-2-1986. In this letter, Income-tax Officer asked assessee specifically to explain credits in partners' account in subsequent assessment year and that Explanation 2 to section 271(1) (c) was applicable to assessee's case. CIT (Appeals) has confirmed this penalty, stating as follows: "Concealment of income and furnishing of inaccurate particulars has taken place in return of income filed by assessee on 28th April, 1984. It is not possible to accept contention of learned representative that revised return filed on 22-12-1984 was filed voluntarily and in order to purchase peace. Explanation 2 to section 271(1) (c) of Income-tax Act squarely applies to facts of this case as assessee had credited accounts of partners with sum of Rs. 2,50,000 in subsequent year." 4. Before us, learned representative of assessee submitted that it was not enough for department to rely on Explanation 2 but it was also necessary for them to show that assessee had actually concealed income in relevant assessment year. He also argued that it was necessary for department to prove that concealment had taken place in earlier assessment year and that penalty could have been levied in that year. He also relied upon following decisions: (i) CIT v. Anwar Ali [1970] 76 ITR 696 (SC); (ii) CIT v. Ashoka Marketing Ltd. [1976] 103 ITR 543 (SC); and (iii) Anantharam Veerasinghaiah & Co. v. CIT [1980] 123 ITR 457 (SC). 5. On other hand, learned departmental representative replied that revised return was not voluntarily filed but was prompted by Income-tax Officer's questioning. He relied upon said Explanation 2 and emphasised that this was clear case where assessee had concealed income because in very next year assessee had brought that amount in books as capital of partners. 6. simple fact in this case is, as stated at outset, that sum as large as Rs. 2,50,000, was found credited to capital account of partners in very next year. After revised return for earlier year was filed this sum was claimed as not belonging to assessee. question that arises is where this sum came from? obvious conclusion must be that revised return whereby this sum was offered for taxation did not state truth as claimed by assessee. clear inference is that it was income of assessee in assessment year 1983-84 and that false statement was made by assessee to department that this sum may be 'treated as income o f assessee' only in order to buy peace. audacity of assessee is seen from its letter dated 21-12-1985 in which it had stated that revised return was accepted by Income-tax Officer implying that Income-tax Officer having excited that return could not now initiate penalty proceedings. Thus, entire move of assessee was to file revised return disclosing higher income so that if Income-tax Officer accepts same that additional amount could be brought in books of company without any penal liability for concealment. This cannot be accepted. With regard to submission of assessee's representative that penalty could have been levied in earlier assessment year, it is all too plain that but for fact that assessee filed false revised return claiming in substance that amount was not its income, 'but could be treated as such only to buy peace', penalty would have been imposed in that year. Furthermore, Explanation is intended to get over this difficulty. Regarding argument that something more is necessary than merely Explanation, what more is required than glaring fact that in very next year such large sum as Rs. 2,50,000 has been found credited in partner's accounts? cases relied upon by learned representative are not applicable since they were decided before introduction of aforesaid Explanation. assessee had raised plea of limitation, but learned CIT (Appeals) has effectively dealt with it. It was assessee's contention in grounds of appeal that penalty proceedings were initiated only on 31-12- 1985, but CIT (Appeals) has stated that they were initiated at time of passing assessment order on 28-12-1984. This has not been denied by assessee's representative. 7. In result, we confirm order of CIT (Appeals) and reject this appeal. *** CALICUT TRADING CO. v. INCOME TAX OFFICER