2026 (3) TMI 129

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.... from the penalty order passed under section 271(1)(c) of the Act, for the assessment year 2009-10. 2. In this appeal, the assessee has raised the following grounds: - "1. On the facts and in the circumstances of the case and in law, the penalty proceedings initiated u/s 271(1)(c) of the Act is invalid and bad in law. 2. On the facts and in the circumstances of the case and in law,the penalty order levying a penalty of Rs 3,01,600/- passed u/s 271(1)(c) of the Act is invalid and bad in law. 3. On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in dismissing the appeal and confirming the penalty levied of Rs 3,01,600/-u/s 271(1)(c) of the IT Act. 4. On the facts and i....

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....ting to Rs. 1,22,03,666/- by the assessee. In further appeal, the learned CIT(A) enhanced the addition to 100% of the total non-genuine purchases. The Coordinate Bench of the Tribunal, in further appeal by the assessee in quantum proceedings, vide order dated 01.10.2021 passed in ITAs No. 735- 737/Mum/2020, for the assessment years 2009-10 to 2011-12, restricted the disallowance to 8% of the bogus purchases and thus granted partial relief to the assessee. 5. In the meanwhile, penalty proceedings under section 271(1)(c) of the Act were initiated separately by the AO for the year under consideration. After considering the submissions of the assessee, the AO vide order dated 15.03.2022 passed under section 271(1)(c) of the Act, levied a pen....