Estimated Commission Addition Cannot Trigger Concealment Penalty: ITAT Mumbai

Amish Anantrai Modi Vs DCIT (ITAT Mumbai) The appeal before the Income Tax Appellate Tribunal arose from a penalty order passed under section 271(1)(c) of the Income-tax Act, 1961 for Assessment Year 2011–12. The assessee challenged the order of the Commissioner of Income-tax (Appeals), which had confirmed the penalty imposed by the Assessing Officer. The original assessment was completed under section 143(3) read with section 153C, determining income higher than the returned figure. Subsequently, reassessment proceedings were initiated under section 147, during which the Assessing Officer a...