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    <title>2023 (10) TMI 511 - ITAT MUMBAI</title>
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    <description>Penalty under section 271(1)(c) was considered unsustainable where the addition arose only from an estimated gross profit element on alleged bogus purchases. The assessee had produced purchase and sales records, stock details, invoices, delivery challans, ledger confirmations, banking proof and quantitative statements, and these were not shown to be false or incorrect. As the trading results and quantitative details were not disturbed and no enquiry established purchases outside the books or denial by the suppliers, the estimated addition was treated as an inference of suppressed profit rather than proof of concealment or inaccurate particulars. Penalty was therefore deleted.</description>
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      <description>Penalty under section 271(1)(c) was considered unsustainable where the addition arose only from an estimated gross profit element on alleged bogus purchases. The assessee had produced purchase and sales records, stock details, invoices, delivery challans, ledger confirmations, banking proof and quantitative statements, and these were not shown to be false or incorrect. As the trading results and quantitative details were not disturbed and no enquiry established purchases outside the books or denial by the suppliers, the estimated addition was treated as an inference of suppressed profit rather than proof of concealment or inaccurate particulars. Penalty was therefore deleted.</description>
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