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 the

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