2019 (2) TMI 114

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....pugned order dated 1.5.2018 passed by Ld. CIT(A) 29 New Delhi in relation to the penalty proceedings u/s 271(1)(c) for the assessment year 2011-12. The assessee is mainly aggrieved by levy of penalty of Rs. 3,09,000/- made on account of disallowance of commission /brokerage on purchases. 2. The facts in brief are that assessee was engaged in the business of manufacturing of garments of various br....

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.... lacs was made in the quantum proceedings on the ground that brokerage /commission could not be proved to be genuine, although the copy of confirmation, income tax return etc. filed by the parties directly before the AO in response to summon made u/s 131. The sole reason for disallowance in the quantum proceedings was that, none of these persons could be produced for a deposition when the assessee....