Section 271(1)(c) Penalty not sustainable on mere estimated additions

Sri Saibaba Swamigal Thirumana Mandapam Vs ITO (ITAT Chennai) Facts- The assessee being resident firm is stated to be engaged in renting out marriage halls. It was assessed u/s. 143(3) of the Act on 28.02.2013. The assessee was subjected to survey action u/s. 133A on 16.09.2009 wherein a register containing the details of number of marriages and other small functions conducted during financial years 2006-07 to 2009­10 was found and impounded. Based on the same, it was alleged by AO that there was suppression of rental receipts to the extent of Rs.47.30 Lacs and accordingly, the same was added...