The High Court, affirming the order of the Tribunal, held that penalty under section 271(1)(c) is not leviable where additions on alleged bogus purchases are made merely on an estimated basis, in the absence of cogent evidence of concealment or furnishing of inaccurate particulars. The Hon’ble Court also observed that estimation of profit and reliance on undisclosed third-party information cannot constitute a valid basis for penalty. (AY. 2011-12).