2024 (1) TMI 209

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.... For the Assessee : Shri Rahul Sarda For the Revenue : Smt. Mahita Nair ORDER PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against order dated 23/03/2023 passed by NFAC, Delhi in relation to penalty proceedings u/s. 271(1)(c) for the A.Y.2007-08. 2. Assessee is aggrieved by penalty of Rs. 5,68,596/- on account of addition made by applying GP rate of a....

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....tock register entry and cheque payments, custom appraisal report in respect to export sales, however, the ld. AO held that delivery challan etc. were not produced during the course of assessment proceedings. Based on such investigation report, ld. AO treated the entire purchases of Rs. 5,57,61,124/- as unexplained. In the first appeal, ld. CIT (A) had reduced the addition by restricting it to 3% o....

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....imate of gross profit rate. From the perusal of the records, it is seen that the assessee has submitted the quantitative details of purchases alongwith stock register entry and corresponding export sales which was also verified from the customer appraisal report. Once, the source of payment of purchases have been made through books of accounts and through account payee cheques and there is corresp....