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2014 (11) TMI 1099 - GUJARAT HIGH COURTPenalty levied under Section 271(1)(c) - no return of income had been filed by the assessee - Held that:- The penalties were upheld as it was only estimated value on which estimates of income tax was made and the books of accounts were rejected. There was no scope to levy the penalty under Section 271(1)(c), the appellant had been assessed by the Income Tax. The Tribunal has very rightly considered that both the additions are on an estimated basis. Therefore, just because estimates are made, penalty cannot be levied under Section 271(c). We are unable to persuade ourselves to take a different view than that taken by the Tribunal as well as CIT (Appeals)
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