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2021 (8) TMI 845 - AT - Income TaxPenalty u/s. 271(1)(c) - additions made on account of bogus purchases - HELD THAT:- AO has made addition on the basis of estimated addition and consequently imposed penalty under section 271(1)(c) of the Act. In our considered opinion, and keeping in view the consistency maintained by this Tribunal in plethora of cases that the provisions of section 271(1)(c) of the Act are not attracted to cases where income of an assessee is assessed on estimate basis and addition is made therein on that basis. In the present case also, the facts are similar and hence no penalty ought to have been levied by the Assessing Officer. Even otherwise also, the Revenue has not adduced any cogent material before us to demonstrate that the order passed by the learned CIT(A) deleting the penalty imposed by the Assessing Officer under section 271(1)(c) of the Act is void ab initio. - Decided against revenue.
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