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2021 (4) TMI 1340 - AT - Income TaxMaintainability of appeal on low tax effect - Penalty levied u/s.271(1)(c) - addition made on account of bogus purchases - Penalty deleted by the CIT(A) on the primary ground that no penalty would survive on an estimated addition - HELD THAT:- We find that the exception provided in para 10(e) of the Circular 17/2019 dated 08/08/2019 is applicable only for the quantum proceedings and the same cannot be made applicable for penalty proceedings. It is well settled that penalty and quantum assessment proceedings are distinct and separate. Accordingly, we dismiss this appeal of the Revenue by following the aforesaid Circular No.17/2019 dated 08/08/2019 and hold that the appeal of the Revenue is not maintainable.
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