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2022 (2) TMI 181 - AT - Income TaxPenalty u/s 271(1)(c) - ad-hoc addition/disallowance - disallowance of 25% of the various expenses claimed by the assessee - HELD THAT:- The only reason given by the AO for making such disallowance on estimate or on ad-hoc basis was the unverifiable element involved in the said expenses, compliance of TDS provisions etc. It is noted that while making such disallowance, the AO has not pointed out even a single instance of any bogus expenditure claimed by the assessee. He has also not brought any adverse material on record to establish that the assessee was guilty of concealing of particulars of its income or furnishing inaccurate particulars of such income. We are of the view that the penalty imposed by the Assessing Officer under Section 271(1)(c) of the Act and sustained by the learned CIT(A) in respect of additions made on estimated basis on account of disallowance of expenses on ad-hoc basis is not sustainable; and, cancelling the same, we allow this appeal of the assessee.
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