Penalty cannot be imposed on additions purely based on estimation of income

Shri Shailendra Jhanwar Vs ITO (ITAT Jodhpur) Ld. Counsel for the assessee submitted that penalty order did not specify the charge. Further, the penalty was imposed purely on the basis of estimation of income. He submitted that under the facts and circumstances of the present case, the authorities below should not have imposed the penalty. He placed reliance on the decision of Co-ordinate Bench of the Tribunal in the case of ITO vs Shri Uday Kumar D.Bhatt in ITA No.2072/Ahd./2018 & C.O.No.75/Ahd./2018 for AY 2014-15 order dated 06.08.2021. We have heard Ld. Authorized Representatives of t...