https://www.taxtmi.com/caselaws?id=13841 Penalty under s.271(1)(c) was examined where additions were sustained by the tax authority through multi-stage estimates drawn from seized material, including extrapolation from identified unaccounted purchases, further enhancement for ancillary items, rounding off, and inferring corresponding sales. The HC held that seized documents must be read as a whole, and further estimations or selective inferences are impermissible absent cogent supporting material; therefore, the addition based on such estimates could not establish "fraud" or "gross or wilful neglect" so as to attract the Explanation to s.271(1)(c). In any event, the assessee rebutted the Explanation's presumption on the assessment record. The penalty was set aside. en-us Thu, 19 Jul 2001 00:00:00 +0530 Mon, 22 Dec 2025 16:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13841 Penalty under s.271(1)(c) was examined where additions were sustained by the tax authority through multi-stage estimates drawn from seized material, including extrapolation from identified unaccounted purchases, further enhancement for ancillary items, rounding off, and inferring corresponding sales. The HC held that seized documents must be read as a whole, and further estimations or selective inferences are impermissible absent cogent supporting material; therefore, the addition based on such estimates could not establish "fraud" or "gross or wilful neglect" so as to attract the Explanation to s.271(1)(c). In any event, the assessee rebutted the Explanation's presumption on the assessment record. The penalty was set aside. Case-Laws Income Tax Thu, 19 Jul 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13841