2025 (10) TMI 856

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.... from the penalty order passed under section 271(1)(c) of the Act, for the assessment year 2012-13. 2. The present appeal is delayed by 250 days. Alongwith the appeal, the assessee has filed an application seeking condonation of delay, which is duly supported by his affidavit, submitting as follows: - "6. I being aggrieved by the said order has filed appeal before CIT(A) on 06.05.2019 contesting the levy of penalty. The Hon'ble CIT(A) NFAC has passed the Order u/s 250 of the Income Tax Act, 1961, dated 23rd August, 2024 under DIN reference no. ITBA/NFAC/S/250/2024 - 25/1067929078(1) confirming the levy of penalty by dismissing the appeal. I was not aware of the CIT(A)'s order as the same was sent on email of my part-time....

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....d from the office of DGIT (Inv.) Mumbai, the assessee is a beneficiary of accommodation entry transaction of bogus purchases from entities which are controlled by Bhanwar Lal Jain and Group, show cause notice was issued to the assessee regarding the tendered purchases. Vide order dated 27.03.2015 passed under section 143(3) of the Act, the Assessing Officer ("AO") made an addition of Rs. 8,96,442/- by treating the purchases as bogus and by applying the gross profit rate of 8%. In further appeal, the learned CIT(A), in quantum proceedings, directed that the profit margin already declared by the assessee in its books should be reduced from the profit margin of 8% adopted by the AO for the alleged bogus purchases. Accordingly, the learned CIT(....