Valuation Dispute: ITAT Quashes Penalty U/S 271(1)(c) as Addition Was Solely Based on Estimate

Yogesh Jashubhai Patel Vs ITO (ITAT Ahmedabad) Mere difference in valuation or estimation does not constitute concealment or furnishing of inaccurate particulars. Ahmedabad ITAT allowed both the quantum &  penalty appeals of Assessee, holding that the delay in filing appeal was bona fide &  that the addition to Long-Term Capital Gains (LTCG) was unsustainable in law. Assessee, a Non-Resident Indian (NRI), sold his share in agricultural land &  declared LTCG of ₹1.56 lakh, adopting cost of acquisition at ₹1.25 lakh (as on 01.04.1981) based on a registered valuer’s report. A...