https://www.taxtmi.com/caselaws?id=69920 Penalty under section 271(1)(c) was held unsustainable where no return had been filed for the relevant assessment year and the additions were made on estimated income. Explanation 5 could not be invoked because it is a deeming provision confined to money, bullion, jewellery or other valuable article or thing found in search, and it cannot be extended to estimated additions that do not involve such search assets. The legal fiction was required to operate strictly within its statutory scope, so the penalty was deleted. en-us Mon, 20 Oct 2008 00:00:00 +0530 Mon, 06 Aug 2012 16:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69920 Penalty under section 271(1)(c) was held unsustainable where no return had been filed for the relevant assessment year and the additions were made on estimated income. Explanation 5 could not be invoked because it is a deeming provision confined to money, bullion, jewellery or other valuable article or thing found in search, and it cannot be extended to estimated additions that do not involve such search assets. The legal fiction was required to operate strictly within its statutory scope, so the penalty was deleted. Case-Laws Income Tax Mon, 20 Oct 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69920