Court Rules No Penalty u/s 271(1)(c) for Estimated Disallowance of 50% on Commission and Improvement Costs.

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....Levy of penalty u/s.271(1)(c) - estimation of disallowance at 50% of commission and improvement expenditure - in this case, the additions were made on the basis of estimation and as discussed in the cases referred above, the penalty cannot be levied on the basis of estimated additions and thus, it is not a fit case for levying penalty. - AT....