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Issues: Whether penalty under section 271(1)(c) of the Income-tax Act, 1961 was sustainable where the surviving addition was made only on estimation and did not establish concealment of income or furnishing of inaccurate particulars.
Analysis: The remaining addition sustained in the quantum proceedings was small and had been determined on an estimated basis. On those facts, the case did not disclose deliberate concealment or inaccurate particulars so as to justify penalty under section 271(1)(c).
Conclusion: Penalty under section 271(1)(c) was not exigible and was deleted in favour of the assessee.
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