Penalty on Estimated Income Cannot Stand: ITAT Dehradun Deletes 271(1)(c) Levy Partly

Puran Chan & Co. Vs DCIT (ITAT Dehradun) The ITAT held that penalties under Section 271(1)(c) cannot be levied on estimated income, deleting the portion of the penalty attributable to such estimates while sustaining penalty on confirmed additions. Emphasizing that penalties must be based on precise, verifiable income particulars—not assumptions—the Tribunal reaffirmed that only actual taxable income can trigger concealment or inaccurate-particulars penalties. This appeal concerned penalty u/s 271(1)(c) levied after the quantum order u/s 143(3). Assessee argued that the penalty notice ...