Section 270A Penalty Deleted as Estimated Profit Addition Cannot Prove Misreporting

Nikhil Kumar Bansal Vs ITO (ITAT Agra) The ITAT Agra deleted a penalty of ₹1,10,240 levied under Section 270A(9) for alleged misreporting of income, holding that penalty cannot be sustained where the underlying addition is based purely on estimation. The assessee, engaged in trading of mustard cake, mustard oil, and related commodities, had faced an addition in assessment proceedings after the Assessing Officer treated certain purchases as non-genuine and estimated the profit element embedded therein at 12.5% of the disputed purchases. The assessee accepted the addition to avoid prolonged li...