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TMI Blog2019 (6) TMI 1114X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee against the order dated 20.07.2018 of the Commissioner of Income Tax (Appeals)-3, Ludhiana [hereinafter referred to as 'CIT(A)']. 2. The sole issue raised in this appeal relates to the levy of penalty u/s 271 (1)(c) of the Act in respect of the quantum additions sustained by the Ld. CIT(A). 3. The appeal is time barred by limitation period of 39 days. The assessee has moved a separate ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sers who used to handover certain amounts for the purchase of the vehicles of their choice through the assessee and as and when such vehicles are found available for the sale. However, the Assessing Officer did not get satisfied with the above explanation of the assessee and made the addition of Rs. 8.41 lacs taking the figure of peak cash credited in the account of the assessee. Apart from that, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... quantum additions, however, in the present appeal, the assessee has contested the levy of penalty u/s 271 (1)(c) of the Act. 6. I have considered the rival contentions. In this case Ld. Counsel for the assessee has explained that the assessee was engaged in the activity of sale and purchase of old vehicles and that the customers used to deposit certain amounts with the assessee so that the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ircumstances, it is apparent that the impugned additions have been made by the lower authorities on estimation basis. However, there was no reliable or un-rebutted evidences on the file to prove that the assessee had actually furnished inaccurate particulars of income or concealed particulars of his income. Though, the additions have been made by the Assessing Officer and further confirmed by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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