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The Tax Publishers2019 TaxPub(DT) 4502 (Del-Trib) INCOME TAX ACT, 1961
Section 271(1)(c)
Since penalty cannot be levied on addition on the basis of estimated disallowance, therefore, penalty imposed under section 271(1)(c) on account of ad-hoc disallowance of expenses, was not justified.
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Penalty under section 271(1)(c) - Penalty whether sustainable on the basis of estimated disallowances/additions - Validity of -
Penalty was imposed under section 271(1)(c) by AO along with addition made towards ad-hoc disallowances of expenses. Assessee contended that imposition of penalty was unjustified. Held: Penalty cannot be levied on addition on account of estimated disallowance. Therefore, penalty imposed under section 271(1)(c) on account of ad-hoc disallowance of expenses, was not justified.
Followed:CIT v. Reliance Petro Products (P) Ltd. (2010) 322 ITR 158 (SC) : 2010 TaxPub(DT) 1683 (SC)
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
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