Penalty u/s 271(1)(c) Not Imposed Due to Opinion-Based Estimate Differences; No Evidence of Concealment Found.

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....Penalty levied u/s 271(1)(c) - Since the difference in estimates was based on a difference of opinion and the revenue did not bring to notice any positive proof regarding concealment of income by the assessee, no hesitation in concluding that it is not a case fit for levy of penalty.... - AT....