Estimated bogus purchase additions cannot by themselves sustain concealment penalty; non-considered submissions required remand.

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....Penalty under Section 271(1)(c) was held unsustainable where the underlying quantum addition for alleged bogus purchases represented only an estimated profit element and not a definite, proved concealment. The ITAT deleted the penalty for Assessment Year 2010-2011 on the ground that estimated additions alone do not justify penalty. For Assessment Year 2011-2012, the appellate order sustaining penalty was set aside because the assessee's submissions had not been considered; the matter was remanded for fresh adjudication after giving reasonable opportunity and addressing the material placed on record.....