Penalty u/s 271(1)(c) Inapplicable for Additions Using Peak Credit Theory

Edward Sam Vs ITO (ITAT Chennai) In the case of Edward Sam Vs. Income Tax Officer (ITO) heard at ITAT Chennai, The appeal challenges the penalty under section 271(1)(c) of the Act imposed on the taxpayer for alleged concealment of income.  Tribunal analyzes the application of penalty provisions and the use of peak credit theory for quantum additions. Edward Sam, a retired BHEL employee, filed his return for AY 2011-12, showing an income of 2,92,178/- after deducting house property loss. The assessment was completed under section 143(3) by adding ₹.25,00,000/- under section 69A for cash depo...