Promissory note presumption of consideration survives blank-signature and income-tax non-disclosure objections when admissions and attesting evidence ...
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The Appellate Tribunal held that penalty u/s 271(1)(c) on estimated additions due to bogus purchases from hawala dealers was unjustified as the assessee failed to provide detailed information requested by the AO. The AO estimated the income at 9%, later reduced to 5% by CIT (A). The Tribunal cited similar cases where penalties were not upheld for estimated income additions. The Tribunal rejected the argument that low tax effect appeals by Revenue were invalid, stating that appeals on issues of addition and penalties based on specified information are permissible. The decision favored the assessee.
The Appellate Tribunal held that penalty u/s 271(1)(c) on estimated additions due to bogus purchases from hawala dealers was unjustified as the assessee failed to provide detailed information requested by the AO. The AO estimated the income at 9%, later reduced to 5% by CIT (A). The Tribunal cited similar cases where penalties were not upheld for estimated income additions. The Tribunal rejected the argument that low tax effect appeals by Revenue were invalid, stating that appeals on issues of addition and penalties based on specified information are permissible. The decision favored the assessee.
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