Assessing Officer made addition on basis of difference between value declared by assessee and value determined by DVO . The AO levied the penalty for underreporting of income . On appeal the Tribunal held  that only basis of addition made was estimate made by DVO, said addition made on basis of estimation could not provide foundation for under-reported income for purpose of imposition of penalty under section 270A and thus, penalty was to be deleted . ( AY. 2017 -18 )