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2017 (1) TMI 111 - AT - Income TaxPenalty u/s 271(1)(c) - suppression of receipts - discrepancy in accounting the professional receipts found during survey - Held that:- The income of the assessee was assessed purely on estimated basis which is further fortified by the fact that addition was reduced by the FAA and also by the tribunal in quantum appeal. In our view, it is trite law that in case difference of opinion, where the addition is made on the basis of estimation, conjecture and surmises, the penalty u/s 271(1)(c) cannot be levied. We are, therefore ,inclined to set aside the order of the ld.CIT(A) and direct the AO to delete the penalty. - Decided in favour of assessee
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