Tax Evasion through Shell Companies in Real Estate

Akhil Gupta, a businessman, has been accused of tax evasion. He has a network of shell companies that are involved in buying and selling luxury properties in Mumbai. The government has found out that Akhil is actually the beneficial owner of these companies, but he has not declared his income from these transactions in his tax returns.

What would be the legal outcome if the government charges Akhil under Section 271(1)(c) of the Income-tax Act, 1961, for attempting to evade tax through these shell companies? Would he be able to defend himself by saying that he didn't have the intention to evade tax, or would the courts consider the fact that tax evasion occurred nonetheless? Can the government impose penalties and impose a higher tax rate under this section?