TMI Blog2016 (3) TMI 1158X X X X Extracts X X X X X X X X Extracts X X X X ..... respect of unverifiable purchases, he has taken the recourse of assessing the income of the assessee merely on estimated basis. Thus mere estimation for quantum addition should not be made the basis for levy of concealment penalty. Reliance can be placed on Ajaib Singh and Co. vs. CIT (2001 (8) TMI 79 - PUNJAB AND HARYANA High Court ), Navjivan Oil Mills vs. CIT (2001 (7) TMI 81 - GUJARAT High ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n of loss of ₹ 7,21,357/- was declared. The AO has examined the reasons of the loss. It was explained that during the year sales to the tune of ₹ 41,62,599/- was made and the gross profit was at ₹ 3,03,572/-. However, due to expenditure on interest, depreciation, rent, wages etc., a net loss was suffered. The AO has examined the records of the assessee and the undisputed fact ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... imposed of ₹ 25,245/-. 3. In the light of the above factual background on this small issue heard both the sides. 4. As per the above facts, the admitted factual position is that one estimation was made by the AO and that estimation was revised by ld. CIT (A) and made another estimation. In other words, this is a case where the assessee is penalized on account of one estimation against ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of making certain specific addition in respect of unverifiable purchases, he has taken the recourse of assessing the income of the assessee merely on estimated basis. I have also perused the decision cited by the ld. D/R referred above. But the facts were that the revenue department had detected that some of the parties have given accommodation entry and also found that the accommodation bills we ..... X X X X Extracts X X X X X X X X Extracts X X X X
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