TMI Blog2021 (3) TMI 652X X X X Extracts X X X X X X X X Extracts X X X X ..... a sum in addition to taxes, if any, payable him, which shall not be less than but which shall not exceed three times the amount of tax sought to be evaded by reason of concealment of income and furnishing of inaccurate particulars of income. The quantification of the penalty is depended upon addition made to the income of the assessee. Since in the present case, basis for visiting the assessee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... IT(A) has erred in confirming the penalty imposed by the AO under section 271(1)(c) of the Income Tax Act, 1961 amounting to ₹ 9,97,256/-. 3. Brief facts of the case are that the assessee company was engaged in the providing consultancy services. It has filed its return of income on 29.9.2012 declaring total income at ₹ 92,14,300/-. An assessment order was passed on 19.1.2015 under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... This MA was allowed by the Tribunal vide order dated 1.1.2019 and the appeal was restored to its original number. The appeal again heard by the Tribunal on 17.6.2019. The order was pronounced on 11.9.2019. The assessee found certain apparent mistake in the order of the Tribunal, and therefore, filed another MA bearing no.324/Ahd/2019 on 4.10.2019. This application was listed before the Tribunal on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... disallowance of alleged bogus expenditure of ₹ 25,30,500/-. Both the additions stand deleted at the end of the Tribunal vide order dated 10.11.2020 passed in ITA No.772/Ahd/2016. The ld.DR was unable to controvert this factual position. 5. On due consideration of the above facts and circumstances, we find that sub-clause (iii) of section 271(1)(c) provides mechanism for quantification of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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