2025 (9) TMI 231

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....ER SECTION 254(1) OF INCOME TAX ACT PER PAWAN SINGH, JUDICIAL MEMBER; 1. This appeal by assessee is directed against the order of ld. CIT(A)/NFAC, Delhi dated 05.02.2025 for A.Y. 2007-08. The assessee has raised following grounds of appeal: "1. In the facts and circumstances of the case and in law, the learned CIT(A) erred in holding that penalty @ 100% of tax sought to be evaded u/....

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....ddition of Rs. 1.86 crores, being 100% of purchases shown from Jewel Diam and Daksh Diamonds. However, on appeal before ld. CIT(A), such disallowances were restricted to 3.00% of the disputed purchases/ alleged bogus purchase. In the meantime, the assessing officer levied penalty under section 271(1)(c) at 100% of tax sought to be evaded. The assessing officer levied on the penalty of Rs. 63,39,13....

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....presentative (ld. CIT-DR) for the revenue supported the order of lower authorities. 4. We have considered the rival submissions of both the parties and perused the orders of lower authorities carefully. We have also deliberated on various case laws relied by ld. AR of the assessee. We find that there is no dispute that addition in the quantum assessment was ultimately restricted to 3.00 % of th....