Appeal on Low Tax Effect Dismissed; Penalty u/s 271(1)(c) Not Covered by CBDT Circular No. 3/2018 Exception.

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....Maintainability of appeal - low tax effect - Penalty - Since the levy of penalty by no means could be construed as an addition within the meaning of Para 10(e) of the aforesaid circular, therefore, we do not find any merit in the claim raised by the revenue that the aforementioned exception carved out in the CBDT Circular No. 3/2018 (supra) would also take within its sweep penalty imposed by the A.O. under Sec. 271(1)(c) of the Act in respect of an addition of bogus purchases on the basis of an information received from Sales Tax Authorities i.e. an external agency. - AT....