Penalty under section 271(1)(c) is not leviable on an alleged bogus-purchase addition that survives only as an ad hoc or estimated disallowance. The disallowance was restricted in appeal to an estimated percentage of the purchases. Following the coordinate-bench approach on estimated additions, the penalty was deleted and the assessee's appeal was allowed. An estimated disallowance for alleged bogus purchases, by itself, did not sustain the imposed penalty.
Penalty under section 271(1)(c) is not leviable on an alleged bogus-purchase addition that survives only as an ad hoc or estimated disallowance. The disallowance was restricted in appeal to an estimated percentage of the purchases. Following the coordinate-bench approach on estimated additions, the penalty was deleted and the assessee's appeal was allowed. An estimated disallowance for alleged bogus purchases, by itself, did not sustain the imposed penalty.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
