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TMI Blog2019 (3) TMI 1162X X X X Extracts X X X X X X X X Extracts X X X X ..... in addition to taxes, if any, payable him, which shall not be less than but which shall not exceed three times the amount of tax sought to be evaded by reason of concealment of income and furnishing of inaccurate particulars of income - the quantification of the penalty is depended upon the addition made to the income of the assessee. Since in the present case, basis for visiting the assessee with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... filed his return of income declaring total loss of Rs.(-)8,45,004/-. An assessment was completed under section 143(3) on 30.12.2011 determining total income at ₹ 42,85,610/-. The AO has disallowed the claim of bad debt amounting to ₹ 50,06,147/-. This amount has been considered by the AO for visiting the assessee with penalty. 4. The ld.counsel for the assessee at the very outset s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r hand, the ld.DR was unable controvert the contentions of the ld.counsel for the assessee. 6. After hearing both sides and considering material available on record, we find that sub-clause (iii) of section 271(1)(c) provides mechanism for quantification of penalty. It contemplates that the assessee would be directed to pay a sum in addition to taxes, if any, payable him, which shall not be les ..... X X X X Extracts X X X X X X X X Extracts X X X X
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