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    <title>2023 (11) TMI 1356 - ITAT SURAT</title>
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    <description>Penalty under section 271(1)(c) was considered in a case where the purchase-related addition was made on estimation and later modified in quantum proceedings. The Tribunal applied the principle that concealment penalty is not ordinarily sustainable when income is determined on an estimated basis, especially where there is no separate finding of concealed income. On those facts, the penalty rested only on the estimated addition and was therefore not leviable; it was directed to be deleted in favour of the assessee.</description>
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      <description>Penalty under section 271(1)(c) was considered in a case where the purchase-related addition was made on estimation and later modified in quantum proceedings. The Tribunal applied the principle that concealment penalty is not ordinarily sustainable when income is determined on an estimated basis, especially where there is no separate finding of concealed income. On those facts, the penalty rested only on the estimated addition and was therefore not leviable; it was directed to be deleted in favour of the assessee.</description>
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