https://www.taxtmi.com/caselaws?id=473181 Concealment penalties under section 271(1)(c) cannot survive deletion of the underlying disallowance under section 40(a)(ia) for non-deduction of tax at source, because deletion removes the penalty's foundation. A concealment penalty is also unsustainable where an expenditure disallowance is retained solely on estimation: the inherent subjectivity of an estimate makes it insufficient as the basis for the penalty. Neither the deleted disallowance nor the estimated expenditure disallowance provides a sustainable basis for the associated penalty. en-us Tue, 29 Apr 2025 00:00:00 +0530 Fri, 06 Nov 2026 13:51:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=473181 Concealment penalties under section 271(1)(c) cannot survive deletion of the underlying disallowance under section 40(a)(ia) for non-deduction of tax at source, because deletion removes the penalty's foundation. A concealment penalty is also unsustainable where an expenditure disallowance is retained solely on estimation: the inherent subjectivity of an estimate makes it insufficient as the basis for the penalty. Neither the deleted disallowance nor the estimated expenditure disallowance provides a sustainable basis for the associated penalty. Case-Laws Income Tax Tue, 29 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=473181