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2020 (10) TMI 505 - ITAT MUMBAIPenalty levied u/s 271(1)(c) - Bogus purchases - HELD THAT:- Imposition of penalty is not automatic. Penalty proceedings are not to be initiated merely to harass the assessee. The approach of the Assessing Officer in this behalf must be fair and objective."Concealment of income" and "furnishing inaccurate particulars" are different. Both concealment and furnishing of inaccurate particulars refer to del/berate acts on the part of the assessee. A mere omission or negligence would not constitute a deliberate act of suppression or furnishing of accurate particulars - See Dilip N. Shroff [2007 (5) TMI 198 - SUPREME COURT] There is no active concealment of income on the part of the assessee and additions made on estimation by the AO do not called for initiation of penalty. Thus, penalty levied by AO has rightly been deleted by Ld. CIT(A). Accordingly, the grounds raised by the revenue stands dismissed.
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