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Penalty under section 271(1)(c) is not leviable on an alleged...

Concealment penalty on estimated bogus-purchase additions is unsustainable where the disallowance rests solely on an ad hoc basis.

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Income Tax October 29, 2026 Case Laws AT
Penalty under section 271(1)(c) is not leviable on an alleged bogus-purchase addition that survives only as an ad hoc or estimated disallowance. The disallowance was restricted in appeal to an estimated percentage of the purchases. Following the coordinate-bench approach on estimated additions, the penalty was deleted and the assessee's appeal was allowed. An estimated disallowance for alleged bogus purchases, by itself, did not sustain the imposed penalty.

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Acts Income Tax