2021 (6) TMI 284

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....l, DR ORDER PER PAVAN KUMAR GADALE, JM: The appeal is filed by the assessee against the order of the Commissioner of Income Tax (Appeals) -21 Mumbai, passed u/s. 271(1)(c) and 250 of the Income Tax Act, 1961. The assessee has raised the grounds of appeal: "1 On the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in confirming penal ty levied b y the Ld....

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....edings has been initiated for concealing of particulars of income or furnishing the inaccurate particulars of income in the show cause notice issued u/s 274 r.w.s 271(1)(c) by stating that neither specific ground was raised on the issue nor any factual details were filed by the appellant during the penal ty proceedings, which is wrong and contrary to the facts of the case, the provisions of IT act....

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..... has made addition of the bogus purchases and disallowance u/sec14A of the act and assessed the total income of Rs. 5,41,45,470/- on 25.03.2014 3.Subsequently,the A.O. has initiated penalty proceedings u/s 271(1)(c) of the Act and found that the assessee against the quantum addition has filed an appeal with the CIT(A). Whereas, the CIT(A) has restricted the disallowance @ 15% of the bogus purc....