TMI Blog2016 (8) TMI 1512X X X X Extracts X X X X X X X X Extracts X X X X ..... ue to possible interpretations of the Act or difference of opinion. It is purely a factual case where the assessee was not able to establish the genuiness of the credits in the assessee s current account in the partnership firm where the assessee is the Managing Partner and other credits in his books of accounts which is elaborately discussed in the orders of the Revenue. These aspects of the c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the crux of the issue is as follows:- The learned Commissioner of Income Tax (Appeals) has erred in sustaining the penalty levied by the learned Assessing Officer under section 271(1)(c) of the Act with respect to the addition made for ₹ 20,78,873/- towards introduction of capital in partners account, ₹ 1,50,000/- and ₹ 6,79,000/- towards unexplained credit 3. Brief fac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4. From the materials produced before us, it appears that the assessee has not preferred any appeal against the orders of the learned Assessing Officer. Subsequently, the learned Assessing Officer levied penalty under section 271(1)(c) of the Act . The learned Commissioner of Income Tax (Appeals) also confirmed the order of the penalty because the assessee could not produce any evidence to justify ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... us the assessee or his representative could not bring out any materials to establish that the additions are made and sustained due to possible interpretations of the Act or difference of opinion. It is purely a factual case where the assessee was not able to establish the genuiness of the credits in the assessee s current account in the partnership firm where the assessee is the Managing Partner a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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