https://www.taxtmi.com/caselaws?id=785156 Where income additions are made on an estimated or percentage basis without concrete evidence of concealment, imposition of penalty under section 271(1)(c) is not justified; additions founded on an estimation of profit do not constitute a positive act of concealment or furnishing of inaccurate particulars, and therefore penalty cannot be sustained. The clarification establishes that ad hoc or estimation based disallowances are insufficient to trigger penal consequences absent independent proof of deliberate concealment, resulting in the reversal of penalty and allowance of the appeal arising from such estimated disallowance. en-us Tue, 25 Nov 2025 00:00:00 +0530 Mon, 19 Jan 2026 07:36:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785156 Where income additions are made on an estimated or percentage basis without concrete evidence of concealment, imposition of penalty under section 271(1)(c) is not justified; additions founded on an estimation of profit do not constitute a positive act of concealment or furnishing of inaccurate particulars, and therefore penalty cannot be sustained. The clarification establishes that ad hoc or estimation based disallowances are insufficient to trigger penal consequences absent independent proof of deliberate concealment, resulting in the reversal of penalty and allowance of the appeal arising from such estimated disallowance. Case-Laws Income Tax Tue, 25 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785156