Estimation-based additions not justify Section 271(1)(c) Penalty: ITAT Rajkot

Anil Abhubhai Odedara Vs ITO (ITAT Rajkot)

In the case of Anil Abhubhai Odedara vs. Income Tax Officer, the Income Tax Appellate Tribunal (ITAT) Rajkot ruled in favor of the assessee, setting aside the penalty levied under Section 271(1)(c) of the Income Tax Act for the assessment year 2013-14. The penalty was based on an addition of ₹5,15,899 made by the Assessing Officer (AO) during the assessment proceedings, derived from an estimated profit of 8% on total contract receipts. The assessee argued that since the addition was based on estimation rather than concrete evide

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