Sh. Anil Talwar, Chandigarh vs Dcit, Cc-Ii, Chandigarh on 7 August, 2018
); CIT v. Devandas Perumal & co. [1983] 140 ITR 943
(Bombay)/[1982]28CTR 211 (Bombay); ACIT v. E. Bhoopathy [1978]
113 ITR 188; ACIT v. Horilal Kunj Behari Lal [1977] 106 ITR 720
(Allahabad); CIT v. Madhab ram bora [1977] 110 ITR 532 (Gauhati);
Rajeev Agarwal, v. ACIT 2012 (9) TMI 442-ITAT, Agra ITA no.
187/Agra/2011. It was also his submission that it is well settled that
penalty under section 271(1)(c) cannot be imposed on the basis of the
DVO's report because the said Report at best is only an opinion on
estimate of investment.