https://www.taxtmi.com/caselaws?id=755744 ITAT Mumbai allowed the assessee's appeal against penalty u/s 271(1)(c). The penalty was imposed on additions made through estimation of manpower costs related to Associated Enterprises. The Tribunal held that additions based on estimation do not attract penalty u/s 271(1)(c). Additionally, the penalty notice u/s 271(1)(c) r.w.s. 274 was defective for not specifying the particular limb of offense - whether concealment of income or furnishing inaccurate particulars. Following jurisdictional HC precedent in Mohd. Farhan A. Shaikh and Karnataka HC decision in SAS Emerald Meadows (upheld by SC), the Tribunal ruled the notice invalid due to lack of specific grounds, resulting in penalty deletion. en-us Tue, 16 Jul 2024 00:00:00 +0530 Thu, 18 Jul 2024 06:54:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755744 ITAT Mumbai allowed the assessee's appeal against penalty u/s 271(1)(c). The penalty was imposed on additions made through estimation of manpower costs related to Associated Enterprises. The Tribunal held that additions based on estimation do not attract penalty u/s 271(1)(c). Additionally, the penalty notice u/s 271(1)(c) r.w.s. 274 was defective for not specifying the particular limb of offense - whether concealment of income or furnishing inaccurate particulars. Following jurisdictional HC precedent in Mohd. Farhan A. Shaikh and Karnataka HC decision in SAS Emerald Meadows (upheld by SC), the Tribunal ruled the notice invalid due to lack of specific grounds, resulting in penalty deletion. Case-Laws Income Tax Tue, 16 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755744