Penalty u/s 271(1)(c) not imposable when addition is on adhoc basis

Shri Poonam K.Prajapati Vs ITO (ITAT Mumbai) ITAT Mumbai held that penalty under section 271(1)(c) of the Income Tax Act not imposable when the addition on account of bogus purchases is done on adhoc/ estimated basis. As, adhoc/ estimated based addition doesn’t tantamount to furnishing of inaccurate particulars of income. Facts- Based on information from DGIT(Inv), AO re-opened the assessment alleging that assessee had obtained accommodation entries/ bogus purchases bills from 6 parties. Accordingly, AO made addition of Rs. 63,52,693/-. Subsequently, the AO has issued notice for levy of pena...