https://www.taxtmi.com/caselaws?id=791481 Penalty under section 271(1)(c) was held unsustainable where the underlying addition for alleged bogus purchases was made only on an estimated profit element and there was no direct evidence of concealment or inaccurate particulars; the penalty was deleted. For the later assessment year, the appellate order could not stand because the assessee's submissions were not considered; the matter was set aside and remanded for fresh adjudication after giving a reasonable opportunity of hearing. The commentary therefore reflects that estimate-based quantum additions do not, by themselves, satisfy the statutory conditions for concealment penalty, and that failure to deal with submissions vitiates the appellate order. en-us Fri, 17 Apr 2026 00:00:00 +0530 Tue, 12 May 2026 08:50:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791481 Penalty under section 271(1)(c) was held unsustainable where the underlying addition for alleged bogus purchases was made only on an estimated profit element and there was no direct evidence of concealment or inaccurate particulars; the penalty was deleted. For the later assessment year, the appellate order could not stand because the assessee's submissions were not considered; the matter was set aside and remanded for fresh adjudication after giving a reasonable opportunity of hearing. The commentary therefore reflects that estimate-based quantum additions do not, by themselves, satisfy the statutory conditions for concealment penalty, and that failure to deal with submissions vitiates the appellate order. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791481