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13. Before adverting to the language of the inserted Explanation, certain broad characteristics in this context call for particular notice with regard to its nature and scope. It seems plain that the statute visualised the assessment proceedings and penalty proceedings as wholly distinct and independent of each other, at least so far as the applicability of the Explanation is concerned. The assessment proceedings necessarily precede and herein are the very foundation of the subsequent penalty proceedings, if any. In true essence, until the assessment proceedings in the shape of the final determination of the assessed income are completed, the provisions of the Explanation could hardly come into play. This is so because the objective and indeed virtually the arithmetical test (which would be elaborated hereafter) is raised basically on the income assessed which has been designated as correct income for this purpose. It is only when this correct income has been determined, that, by comparing it with the returned income of the assessee, the test of the same being less than eighty per cent. of the former can be applied. Again, it is only when this test is satisfied and the case squarely falls within the ambit of the higher levels of concealment that the later part of the Explanation would come into play. Therefore, the assessment proceedings and the penalty proceedings must be kept sharply distinct and independent from each other. Equally axiomatic it is that penalty would follow assessment or, in the reverse, assessment of income by the Department must precede the penalty thereafter, if any, to attract the provisions of the Explanation. It is no doubt true that sometimes, even during the assessment proceedings itself, a notice to show cause why the penalty be not imposed is issued when the disparity between the returned income and the income likely to be assessed is glaringly patent. However, to apply the Explanation in its full rigour and the raising of the demand against the assessee in a case where the returned income is less than eighty per cent. of the assessed income, penalty proceedings can truly be taken only if the correct income has been finalised. However, as the point is not directly before us (and, therefore, has not at all been debated) we do not in any way wish to opine about the validity of a penalty notice issued prior to the determination of the assessed income.