2021 (8) TMI 1421

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.... ORDER PER V. DURGA RAO, JUDICIAL MEMBER: This appeal filed by the assessee is against the order of the learned Commissioner of Income Tax (Appeals), Puducherry in I.T.A. No. 116/CIT(A)-PDY/2017-18 dated 31.07.2018, relevant to the Assessment Year 2010 - 2011. 2. Facts are in brief that there was a survey conducted in the business premises of M/s. Sri Saibaba Guest House on 16th September, 2009....

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.... the penalty proceedings had noted that the total receipt during the period starting from April 2009 to August 2009, as per the impounded Register No. 3 was Rs. 14,98,680/- and the monthly average receipts for this period was Rs. 2,99,736/-. Taking into account the monthly average receipts, i.e. Rs. 2,99,736/-, total lodging receipts for the Financial Year 2009 - 2010 adopted at Rs. 35,96,832/-, w....

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....tive relied on the order passed by the authorities below. 8. We have heard both the sides, perused the materials available on record and gone through the orders of the authorities below. 9. In this case, the Assessing Officer has levied the penalty by taking into consideration only five months of the lodging receipts and estimating for the remaining seven months and the addition is made. 10. In....