In the result, the appeal is partly allowed
Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra
115 to 120 of Paper Book) d) In the case of Subhash Trading Co [1996] 86 Taxman 30 (Gujarat), the Hon'ble Gujarat High Court has upheld that when the addition has been made on the basis of estimate and not on any concrete evidence of concealment, penalty under section 271(1)(c) of the Act is not leviable. (page