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2019 (6) TMI 87 - AT - Income TaxPenalty u/s 271(1)(c) - adhoc disallowance of expenses - Part disallowance of expenditure - HELD THAT:- There cannot be any doubt about the genuineness of expenditure claimed as the Assessing Officer himself has allowed 75% of the total expenditure claimed. The disallowance of 25% is purely on ad–hoc / estimate basis on the allegation that such expenditures are not fully verifiable. There is nothing on record to suggest that the assessee did not furnish full particulars of expenditure claimed or there was any act of omission or commission on the part of the assessee in furnishing the particulars of expenditures. Part disallowance of expenditure claimed is purely on estimate basis. In the aforesaid circumstances, the assessee cannot be accused of furnishing inaccurate particulars of income. More so, when the first appellate authority being convinced with the submissions of the assessee had deleted the disallowance, though of course, such disallowance was restored by the Tribunal. We are inclined to delete the penalty imposed u/s 271(1)(c) - Decided in favour of assessee
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