Addition on estimate basis – Section 271(1)(c) cannot be imposed

Samatbhai Malabhai Parmar Vs ITO (ITAT Rajkot) It is a settled principle of law that where addition to assessee’s income is made on estimate basis penalty under section 271(1)(c) cannot be imposed. The different judicial form has already decided in favour of the assessee on the identical issue, of such is passed in the case of Naresh Chand Agarwal vs. Commissioner of Income Tax by the Hon’ble Allahabad High Court. We have further gone through the written submission made before the authorities below by the appellant. It is on record that the addition was made on estimation of net profit @ 1...