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2023 (9) TMI 594 - ITAT VISAKHAPATNAMPenalty u/s. 271(1)(c) - assessee could not explain the investment to the satisfaction of the CIT(A) - CIT(A) concluded that the assessee has sufficient sources of income for the purpose of investment in the properties as undisclosed - as explained by the assessee did not maintain any books of account during the impugned assessment year as there was no business carried on by the assessee. HELD THAT:- Since the addition is made on estimate basis, various judicial pronouncements have held that penalty cannot be levied when the addition is estimated. We therefore find that the levy of penalty based on the addition made by an estimate cannot be a valid ground and hence it should be deleted. Appeal filed by the assessee is allowed.
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