2026 (2) TMI 984

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.... Mahajan, Sr. DR ORDER PER SANDEEP SINGH KARHAIL, J.M. The Revenue has filed the present appeal against the impugned order dated 10.09.2025, passed under section 250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, ["learned CIT(A)"], which in turn arose from the penalty order passed under section 271(1)(c....

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.... 143(3) read with section 147 of the Act, the Assessing Officer ("AO") made an addition of Rs. 98,103/- under section 69 of the Act, on an estimated basis of 20% of the total purchases found to be bogus. In further appeal, the learned CIT(A) upheld the addition made by the AO. The Coordinate Bench of the Tribunal, in a further appeal by the assessee in quantum proceedings, vide order dated 03.02.2....

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....nder consideration has been made solely on the basis of estimates. 6. We find that the Hon'ble Rajasthan High Court in CIT v/s Krishi Tyre Retreading and Rubber Industries, reported in [2014] 360 ITR 580 (Raj.), held that where an addition is made purely on an estimate basis, no penalty under section 271(1)(c) of the Act is leviable. Similar view has been expressed by the Hon'ble Punjab....