2021 (5) TMI 896

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....RDER Per Saktijit Dey (JM): This appeal by the revenue is against order dated 30-05-2019 of learned Commissioner of Income-tax (Appeals)-16, Mumbai deleting the penalty imposed of Rs. 23, 874/- under section 271(1)(c) of the Income-tax Act for the assessment year 2010-11. 3. We have considered rival submissions and perused the materials on record. Briefly the facts are, the assessee is a resid....

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....g officer found that while deciding assessee's appeal against the disallowance of the purchases, learned Commissioner of Income-tax (Appeals) had granted partial relief to the assessee by disallowing the profit element embedded in the alleged bogus purchases by estimating the same at 12.5%. On the basis of addition sustained by learned Commissioner of Income-tax (Appeals), the assessing officer ul....