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2025 (5) TMI 2046

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.... SANJAY GARG, JUDICIAL MEMBER: The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'CIT(A)'] dated 21/11/2024 for the Assessment Year (AY) 2008-09. 2. The assessee has raised the following grounds of appeal: 1. On facts and circumstances of the case....

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....bsolutely erroneous, incorrect and bad-in-law and needs to be deleted. 3. Without prejudice to the aforesaid ground of appeal no. 2, even otherwise on facts and circumstances of the case and in law, the learned CIT(A), NFAC has grossly erred in confirming the penalty at Rs. 1,53,834/u/s. 271(1)(c) of the Act in respect of the entire additions of Rs. 5,12,779 as confirmed by the learned CIT(A), d....

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..... 5,12,779/-. Even the minor addition of Rs. 36,730/- has been confirmed, only on estimated basis, by applying Gross Profit (GP) rate in respect of deficit in the quantity of goods/cloth sent by the assessee for the job-work against the goods/cloth received from job-workers holding the same was not fully explained. It seems that the impugned minor addition has been confirmed by the Tribunal on est....