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2021 (5) TMI 896 - AT - Income TaxPenalty u/s 271(1)(c) - Estimation of income on bogus purchases - CIT-A deleted the penalty - HELD THAT:- AO had disallowed the entire purchases alleged to be bogus; however, learned Commissioner of Income-tax (Appeals) restricted the disallowance to 12.5% being the profit element estimated on the alleged bogus purchases. Thus the purchase of goods by the assessee is not in doubt, but the source of such purchases is doubtful. For that reason alone, the learned Commissioner of Income-tax (Appeals) has made an estimated addition. In the aforesaid scenario, it cannot be said that the assessee has, either concealed its income or furnished inaccurate particulars of income. That being the case, we do not find any infirmity in the order of learned Commissioner of Income-tax (Appeals) in deleting the penalty imposed. - Decided against revenue.
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