https://www.taxtmi.com/caselaws?id=331083 Penalty under section 271(1)(c) was held unsustainable because the order was passed beyond the limitation period prescribed by section 275(1)(a), and the Revenue did not dispute that the statutory time had expired. On merits, an estimated gross profit addition after rejection of books, and a disputed disallowance of expenditure, were treated as insufficient by themselves to establish concealment or furnishing of inaccurate particulars. The commentary concludes that penalty requires more than an estimate-based addition or a mere disallowance, and that both limitation and substantive conditions must be satisfied for valid penalty action. en-us Mon, 08 Aug 2016 00:00:00 +0530 Fri, 12 Aug 2016 13:21:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331083 Penalty under section 271(1)(c) was held unsustainable because the order was passed beyond the limitation period prescribed by section 275(1)(a), and the Revenue did not dispute that the statutory time had expired. On merits, an estimated gross profit addition after rejection of books, and a disputed disallowance of expenditure, were treated as insufficient by themselves to establish concealment or furnishing of inaccurate particulars. The commentary concludes that penalty requires more than an estimate-based addition or a mere disallowance, and that both limitation and substantive conditions must be satisfied for valid penalty action. Case-Laws Income Tax Mon, 08 Aug 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331083