Section 271(1)(c) Penalty cannot be levied on estimated income: ITAT Surat  

Hetal Ramanlal Shah Vs ITO (ITAT Surat) In the case of Hetal Ramanlal Shah vs. ITO, the Income Tax Appellate Tribunal (ITAT) Surat ruled in favour of the assessee by deleting a penalty levied under Section 271(1)(c) of the Income Tax Act. The dispute arose after the assessee filed a return declaring ₹1.49 lakhs of income for Assessment Year 2008–09, which was later assessed at ₹35.33 lakhs following disallowances of ₹33.73 lakhs under Sections 40A(3)(a) and 40A(3)(b). The disallowances were related to cash payments made for job work and purchases. Based on this assessment, the Assessin...