128. (1) Where, in the course of any proceeding under this Ordinance, the Deputy Commissioner of Taxes, the Appellate Joint Commissioner ¹[, the Commissioner (Appeals)] or the Appellate Tribunal is satisfied that any person has, either in the said proceeding or in any earlier proceeding relating to an assessment in respect of the same income year,- (a) concealed particulars of his income or furnished inaccurate particulars of such income; or (b) understated the value of any immovable property in connection with its sale or transfer with a view to evading tax, ²[he or it shall impose upon such person a penalty of ³[fifteen per cent]] of tax which would have been avoided had the income as returned by such person or, as the case may be, the value of the immovable property as stated by him been accepted as correct ⁴[: ⁵[Provided that if the concealment referred to in clause (a) and (b) of this sub-section or sub-section (2) is detected after a period of more than one year from the year in which the concealment was first assessable to tax, the amount of penalty shall increase by an additional ⁶[fifteen per cent] for each preceeding assessment year.] (2) For the purpose of sub-section (1), concealment of particulars of income or furnishing of inaccurate particulars of income shall include,- (a) the suppression of any item of receipt liable to tax in whole or in part, or (b) showing any expenditure not actually incurred or claiming any deduction therefore. (2A) [Omitted by section 6 of অর্থ আইন, ১৯৯৯ (১৯৯৯ সনের ১৬ নং আইন).] (3) [Omitted by section 7 of অর্থ আইন, ১৯৯৩ (১৯৯৩ সনের ১৮ নং আইন).]