Estimated bogus-purchase additions alone cannot support concealment penalties, requiring deletion where no distinguishing facts or contrary authority exist.

Penalty for concealment or furnishing inaccurate particulars was not leviable where the addition for alleged bogus purchases was ultimately sustained on an ad hoc estimated basis. The reduction of the addition through successive stages demonstrated its estimated nature. Consistent coordinate-bench decisions treated estimated additions, without distinguishing facts or contrary subsequent authority, as insufficient by themselves to support penalty. Applying judicial discipline and consistency, the penalty under section 271(1)(c) was deleted.

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Issues: Whether penalty under section 271(1)(c) was leviable on an addition for alleged bogus purchases ultimately sustained on an ad hoc and estimated basis.

Analysis: The quantum addition was successively reduced from 25% of the alleged bogus purchases to 12.50% and finally to 6%, demonstrating that the sustained addition was estimated. Coordinate Bench decisions on materially identical facts had applied the settled principle that penalty for concealment or furnishing inaccurate particulars is not exigible merely on an ad hoc or estimated addition. No distinguishing factual feature or contrary subsequent authority was shown. Judicial discipline and consistency required adoption of that view.

Conclusion: Penalty under section 271(1)(c) was not leviable on the estimated addition; the penalty was deleted in favour of the assessee.

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