2026 (3) TMI 1565

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.... Revenue : Shri Virabhadra S. Mahajan (Sr. DR) ORDER PER AMIT SHUKLA (J.M): The present appeal has been preferred by the assessee against the order dated 17.10.2025 passed by the learned National Faceless Appeal Centre (NFAC), Delhi, arising out of penalty proceedings initiated under section 271(1)(c) of the Income Tax Act, 1961 for the assessment year 2009-10. 2. The sole grievance of....

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....A), who directed that the penalty be confined to the addition as finally sustained. 3. We have heard the rival submissions and carefully perused the material available on record. It is an undisputed position that the assessee had furnished complete details of purchases, including bills and ledger accounts, and the payments have been made through account payee cheques. The purchases were duly re....

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.... in the books, the element of concealment becomes inherently nebulous and incapable of precise attribution. The assessee's explanation, supported by documentary evidences and banking channels, has not been found to be false; rather, the addition has been sustained only to account for possible inflation of purchase price or profit suppression. 5. Thus, in our considered view, the very edifice of....