Penalty U/s 271(1)(c) Not Sustainable on Estimated Bogus Purchase Addition – ITAT Mumbai Deletes Penalty

Chandan Dhingadmal Jain Vs ITO (ITAT Mumbai) Penalty U/s 271(1)(c) Not Sustainable on Estimated Bogus Purchase Addition – ITAT Mumbai Deletes Penalty The assessee challenged penalty orders u/s 271(1)(c) for AYs 2010-11 & 2011-12 which were levied pursuant to additions made in reassessment proceedings on account of alleged bogus purchases. In quantum proceedings, the AO had added 12.5% of the purchases as profit element, which was later reduced by ITAT to 5%, thereby confirming that the addition itself was purely on estimation basis. The Tribunal observed that penalty for concealment cann...