2025 (1) TMI 1565

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.... PER VIKAS AWASTHY, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals)-27, Delhi (hereinafter referred to as 'the CIT(A)') dated 18.10.2024, for assessment year 2016-17. 2. Shri Paritosh Jain, appearing on behalf of the assessee submits that the Assessing Officer (AO) has levied penalty u/s. 271(1)(c) of the Income Tax Act, 1961(her....

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....ettled legal principle that penalty u/s. 271(1)(c) of the Act cannot be levied on the addition based on estimations. 5. The above proposition has been upheld by different Hon'ble High courts, some of the decisions are as under:- (i) CIT vs. Sangrur Vanaspati Mills Ltd., 303 ITR 53(P&H); (ii) CIT vs. Krishi Tyre Retreading & Rubber Industries, 360 ITR 580(Raj.); & (iii....