TMI Blog2017 (6) TMI 1242X X X X Extracts X X X X X X X X Extracts X X X X ..... sessment to be done denovo. In the regular assessment, the findings were based on the findings for the Assessment Year 1994-1995 wherein the books of accounts were rejected and average rate of 3% of net sales and other income was applied. It was held by the Tribunal that the assessment was based on the preceding year and in fact, in the current year, there was no material, with which the Assessing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e and estimated the profits and said additions had been partly sustained by the Tribunal. In view of that the Tribunal was not justified in deleting the penalty imposed under Section 271 1(c) of the Income Tax Act, 1961. 3 We have considered the submissions. It has been observed by the Tribunal that the impugned assessment was the second round of assessment. In the first round, the CIT (A) had ..... X X X X Extracts X X X X X X X X Extracts X X X X
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