https://www.taxtmi.com/caselaws?id=755678 ITAT Chennai held that penalty under section 271(1)(c) was not sustainable where quantum additions were made on estimated basis using 18.40% net profit rate. The tribunal found that additions sustained were purely estimated and substantial amounts had already been deleted by CIT(A). Following Madras HC precedent in CIT vs. P Rojes and SC ruling in Reliance Petroproducts, the tribunal ruled that incorrect claims in law cannot constitute furnishing inaccurate particulars. The penalty was deleted on merits for all three assessment years. However, legal grounds regarding defective penalty notice were rejected as assessee failed to raise objections during proceedings despite multiple notices. Appeals were partly allowed. en-us Wed, 10 Jul 2024 00:00:00 +0530 Tue, 16 Jul 2024 15:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755678 ITAT Chennai held that penalty under section 271(1)(c) was not sustainable where quantum additions were made on estimated basis using 18.40% net profit rate. The tribunal found that additions sustained were purely estimated and substantial amounts had already been deleted by CIT(A). Following Madras HC precedent in CIT vs. P Rojes and SC ruling in Reliance Petroproducts, the tribunal ruled that incorrect claims in law cannot constitute furnishing inaccurate particulars. The penalty was deleted on merits for all three assessment years. However, legal grounds regarding defective penalty notice were rejected as assessee failed to raise objections during proceedings despite multiple notices. Appeals were partly allowed. Case-Laws Income Tax Wed, 10 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755678