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    <title>Penalties Under Section 271(1)(c) and 271AAB Deleted Where Additions Were Made on Estimate Basis</title>
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    <description>ITAT reversed penalties imposed under s271(1)(c) and s271AAB against assessee regarding disputed cash expenses and labor payments. AO&#039;s additions were initially made at 50%, reduced to 35% by CIT(A), and further reduced to 20% by Coordinate Bench. Despite CIT(A)&#039;s observation of assessee&#039;s alleged malafide intent and mens rea, ITAT held that penalties cannot be imposed on additions made purely on estimate basis, following established precedent. The Tribunal noted AO&#039;s irresponsible approach and lack of judicial discipline in penalty proceedings, particularly given the Coordinate Bench&#039;s prior findings on quantum additions. Appeal allowed in assessee&#039;s favor with complete deletion of penalties.</description>
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    <pubDate>Tue, 25 Feb 2025 08:24:04 +0530</pubDate>
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      <title>Penalties Under Section 271(1)(c) and 271AAB Deleted Where Additions Were Made on Estimate Basis</title>
      <link>https://www.taxtmi.com/highlights?id=86010</link>
      <description>ITAT reversed penalties imposed under s271(1)(c) and s271AAB against assessee regarding disputed cash expenses and labor payments. AO&#039;s additions were initially made at 50%, reduced to 35% by CIT(A), and further reduced to 20% by Coordinate Bench. Despite CIT(A)&#039;s observation of assessee&#039;s alleged malafide intent and mens rea, ITAT held that penalties cannot be imposed on additions made purely on estimate basis, following established precedent. The Tribunal noted AO&#039;s irresponsible approach and lack of judicial discipline in penalty proceedings, particularly given the Coordinate Bench&#039;s prior findings on quantum additions. Appeal allowed in assessee&#039;s favor with complete deletion of penalties.</description>
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      <pubDate>Tue, 25 Feb 2025 08:24:04 +0530</pubDate>
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