2025 (9) TMI 366

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....an, SR. DR ORDER PER AMIT SHUKLA (J.M): These appeals, filed by the assessee, are directed against the separate impugned orders dated 17th December 2024, passed by the National Faceless Appeal Centre (NFAC), Delhi, confirming the levy of penalty under section 271(1)(c) of the Income-tax Act, 1961, for the Assessment Years (AYs) 2010‑11 and 2011‑12. Since the issues involved in....

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....bills. Based on this information, the AO reopened the assessment under section 148 and, during reassessment, applied a gross profit (GP) rate of 12.5% on the alleged non-genuine purchases. 3.1. In AY 2010‑11, the AO made an addition of Rs.5,88,588 on alleged purchases aggregating to Rs.47,08,701, and in AY 2011‑12, an addition of Rs.15,76,897 was made on alleged purchases of Rs.1,26,15....

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....e. 5.1. It is pertinent to note that the sales made by the assessee have not been doubted at any stage, nor has there been any finding that the purchases were not supported by invoices or that the goods were not delivered. The addition has thus been sustained purely to account for a possible inflation of gross profit on account of accommodation entries, and even this estimation has been signifi....