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2021 (4) TMI 164 - AT - Income TaxPenalty u/s. 271(1)(c) - Bogus purchases of raw materials(chemicals) - assessee in order to purchase peace, the assessee came forward to offer 5% as its profit margin in these transactions - HELD THAT:- CIT(A) had categorically given a finding that the addition had been ultimately made only on an estimated basis by placing reliance on the decision of CIT vs. Aero Traders Pvt. Ltd., [2010 (1) TMI 32 - DELHI HIGH COURT], CIT vs. Vijaykumar Jain [2010 (4) TMI 386 - CHHATTISGARH HIGH COURT], CIT vs. Subhash Trading Co. [1995 (11) TMI 37 - GUJARAT HIGH COURT] and MAHENDRA SINGH KHEDLA [2012 (3) TMI 568 - RAJASTHAN HIGH COURT], the ld. CIT(A) held that no penalty u/s. 271(1)(c) of the Act could be levied on an estimated addition and accordingly, deleted the penalty. We do not find any infirmity in the said order of the ld. CIT(A) deleting the penalty on an estimated addition. Accordingly, the ground raised by the Revenue is dismissed.
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