Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (6) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (6) TMI 69 - AT - Income TaxPenalty u/s 271(1)(c) - rejection of books of accounts - addition of 25% on unverifiable/bogus purchases - Held that:- As decided in DEEPAK DALELA, VERSUS I.T.O., WARD-6 (3) , JAIPUR. [2017 (2) TMI 412 - ITAT JAIPUR] in making computation of total income where the income returned has been rejected by rejecting the trading results, finding some discrepancy in the books of account and substituting the same by an estimated figure, in the strict sense, can neither be said to be addition of any amount in the returned income nor disallowance of any amount as deductions claimed. The word ‘‘amount’’ of which additions made or deductions disallowed also denotes reference to specific item of amount added or disallowed as deduction in contrast to substitution of altogether a new estimated sum in place of the income returned. It is a case neither of addition or disallowance but a case of substitution - Accordingly, we delete the penalty levied - Decided in favour of assessee
|