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It has been decided in a number of judgments that when income of assessee was determined on estimation basis of net profit, then no penalty under section 271(1)(c) could be imposed for concealment and furnishing inaccurate particulars.

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Sec. 271(1)(c) of Income Tax Act, 1961— Penalty —When income of assessee was determined on estimation basis of net profit, then no penalty under section 271(1)(c) could be imposed for concealment and furnishing inaccurate particulars, furthermore, the penalty order is fully silent on the issue as to how the satisfaction of concealment/furnishing of inaccurate of particulars of income was arrived at, thus, there was no justification imposing penalty for concealment of income or furnishing of inaccurate particulars of income by the assessee - ANIL ABHUBHAI ODEDARA V/s ITO - [2020] 26 ITCD Online 107 (ITAT-RAJKOT)