TMI Blog2023 (10) TMI 1316X X X X Extracts X X X X X X X X Extracts X X X X ..... o nature and business activity of assessee and also having regard to the non-availability of cogent evidences to support purchases. Significantly, the assessee, in the instant case, has inter alia pointed out that the purchases do not belong to the Assessment Year 2012-13 in question but the amount outstanding against the respective suppliers are opening balances during the year therefore, no e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed appeal has been filed at the instance of the Assessee against the order of the Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre (NFAC), [ CIT(A) in short] dated 11.05.2022 arising from the penalty order dated 11.01.2022 passed by the Assessing Officer (AO) under Section 271(1)(c) of the Income Tax Act, 1961 (the Act) concerning AY 2012-13. 2. As per its grounds of appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as unexplained and accordingly alleged concealment of income at Rs. 3,79,520/- on a total purchase of Rs. 31,62,667/- from these parties. The penalty proceedings were invoked and 100% penalty was imposed on the impugned estimated additions at Rs. 1,17,271/-. 4. In the first appeal, the assessee did not get any relief from the CIT(A). Hence this appeal. 5. We have carefully considered the riv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iture incurred is excessive having regard to nature and business activity of assessee and also having regard to the nonavailability of cogent evidences to support purchases. Significantly, the assessee, in the instant case, has inter alia pointed out that the purchases do not belong to the Assessment Year 2012-13 in question but the amount outstanding against the respective suppliers are opening b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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