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    <title>2024 (1) TMI 209 - ITAT MUMBAI</title>
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    <description>ITAT Mumbai deleted the penalty imposed u/s 271(1)(c) on alleged bogus purchases where addition was made by applying an estimated gross profit rate. The assessee had recorded all purchases in the books, made payments through account payee cheques, and furnished quantitative details, stock register entries and corresponding export sales, which were verified. The addition was purely on an ad hoc GP estimation. ITAT held that such estimated additions cannot sustain penalty for concealment or furnishing inaccurate particulars, particularly where the AO&#039;s satisfaction was vague and invoked both limbs. The assessee&#039;s appeal was allowed.</description>
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      <title>2024 (1) TMI 209 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=447810</link>
      <description>ITAT Mumbai deleted the penalty imposed u/s 271(1)(c) on alleged bogus purchases where addition was made by applying an estimated gross profit rate. The assessee had recorded all purchases in the books, made payments through account payee cheques, and furnished quantitative details, stock register entries and corresponding export sales, which were verified. The addition was purely on an ad hoc GP estimation. ITAT held that such estimated additions cannot sustain penalty for concealment or furnishing inaccurate particulars, particularly where the AO&#039;s satisfaction was vague and invoked both limbs. The assessee&#039;s appeal was allowed.</description>
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