No section 271(1)(c) penalty for additions upheld on estimation basis

Jagubhai Chhaganbhai Patel Vs I.T.O (ITAT Surat)

In this cases in quantum appeals assessee was granted substantial relief in deleting major part of additions and only part of capital gains only on account of cost of improvement on pucca structure was partly upheld on estimation basis. Therefore, all substantial additions were either deleted or upheld only on estimation basis. In our considered view no penalty under section 271(1)(c) of the Act is leviable on this assessee. In the result, the grounds of appeal raised by the a

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