Penalty u/s 271(1)(c) Not Justified for Estimated Disallowance of Bogus Purchases Without Sales Doubt.

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....Levy of penalty u/s 271(1)(c) - disallowance of bogus purchases by applying the profit rate - Once there is no reason to disbelieve the sales made by the assessee and particularly when part of material is recorded in stock, it cannot be justified that the estimation made by the Assessing Officer warrants penalty under section 271(1)(c) - It can be a case of addition or disallowance of bogus purchases on estimate basis but it cannot be a case of levy of penalty for concealment of income under section 271(1)(c) - AT....