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    <title>2024 (5) TMI 103 - ITAT SURAT</title>
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    <description>The ITAT Surat held that penalty under section 271(1)(c) was not sustainable where income additions were made purely on estimation basis regarding bogus purchases. The addition was progressively reduced from 25% at assessment stage to 12.5% in first appeal and finally to 6% before the Tribunal. Since the entire addition was based on estimation without definite findings on quantum of income concealment, the penalty could not be sustained. The Tribunal relied on established legal precedent that penalties under section 271(1)(c) on estimated additions are not maintainable and decided in favor of the assessee.</description>
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    <pubDate>Tue, 30 Apr 2024 00:00:00 +0530</pubDate>
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      <title>2024 (5) TMI 103 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=752050</link>
      <description>The ITAT Surat held that penalty under section 271(1)(c) was not sustainable where income additions were made purely on estimation basis regarding bogus purchases. The addition was progressively reduced from 25% at assessment stage to 12.5% in first appeal and finally to 6% before the Tribunal. Since the entire addition was based on estimation without definite findings on quantum of income concealment, the penalty could not be sustained. The Tribunal relied on established legal precedent that penalties under section 271(1)(c) on estimated additions are not maintainable and decided in favor of the assessee.</description>
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      <pubDate>Tue, 30 Apr 2024 00:00:00 +0530</pubDate>
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