Estimated Profit Penalty Deleted: Reason Why 271(1)(c) Cannot Apply to Estimated Income Additions

Samir N. Shah Vs ITO (ITAT Mumbai) Only Estimate, No Evidence: ITAT Strikes Down 271(1)(c)- When income is enhanced only by applying an estimated profit rate ,without concrete evidence of concealment, 271(1)(c) penalty is not leviable This appeal concerned the validity of penalty u/s 271(1)(c) when the underlying addition was made purely on estimated profit on alleged bogus purchases. Assessee, an individual, filed his return declaring income of ₹23.39 lakh. Based on information from the Investigation Wing that he was a beneficiary of accommodation entries from the Bhanwarlal Jain group, AO ...