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    <description>Penalty for concealment or furnishing inaccurate particulars under section 271(1)(c) was held not sustainable where the addition arose only from estimation of the gross profit element in unproved purchases. The court treated the issue as covered by its earlier view that penalty is not exigible when the income addition rests on pure estimation or guesswork, rather than proved concealment. On that basis, the revenue&#039;s challenge did not raise a substantial question of law, and the penalty issue was answered against the revenue and in favour of the assessee.</description>
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