Income Tax Penalty u/s 271(1)(c) and 274 Deleted Due to Subjective Estimation and Taxpayer's Significant Surrender.

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....Penalty imposed u/s 271(1)(c) read with section 274 - It may be a good case for quantum addition but not for imposing penalty. Estimation is outcome of subjective approach of the individual. If we sustain the part penalty even after a huge surrender made by the assessee then the faith of the assessee will shake. Penalty deleted. - AT....