2021 (2) TMI 419

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....016 for the Assessment Year 2008-09. 2. The assessee has raised the following grounds of appeal:- 1. On the facts and circumstances of the case, the order passed by the Learned Commissioner of Income Tax (Appeals) (CIT(A)) is bad both in the eyes of law and on facts. 2. On the facts and circumstance of the case, the Learned CIT(A) has erred both on facts and in laws in confirming the action of the AO levying penalty amounting to Rs. 6,09,970/- u/s. 271(1)(c) of the Income-tax Act. 3. On the facts and circumstance of the case, the Learned CIT(A) has erred both on facts and in laws in confirming penalty on the additions of Rs. 19,74,026/- made on account of bogus purchases in the order passed under section 143(3)....

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....he penalty is being levied for concealment or for furnishing of inaccurate particulars of income. 9. On the facts and circumstances of the case, the learned CIT(A) has erred both on facts and in law in confirming the penalty despite the fact that there is neither concealment nor furnishing the inaccurate particulars by the assessee. 10. The appellant craves leave to add, amend, or alter any of the grounds of appeal. " 3. The facts of the case shows that assessee filed its return of income on 26.09.2008 at an income of Rs. 1,56,005/-. Later on the case of the assessee was reopened on the basis of the information wherein the assessee was found to be benefited for a sum of Rs. 19,74,026/-. Consequently assessment order und....