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TMI Blog2022 (6) TMI 1190X X X X Extracts X X X X X X X X Extracts X X X X ..... e to 30 per cent. of the purchases. Penalty has been levied on such estimation made by the learned Commissioner of Income-tax (Appeals). Facts of the earlier assessment year also show that estimation was made in respect of purchases from same party which was subsequently reduced to 25 per cent. while giving appeal effect to the order of the Tribunal. When the addition as have been made on es ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ovember 19, 2018 pertaining to the assessment year 2009-10. 2. The solitary grievances of the assessee is that the learned Commissioner of Income-tax (Appeals) erred in sustaining the penalty levied under section 271(1)(c) of the Income-tax Act, 1961 (hereinafter referred to as, the Act ). 3. Roots for levy of penalty lie in the assessment order dated December 19, 2011 framed under section ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2015, following the earlier order of the Tribunal in the assessment year 2008-09, confirmed the findings of the learned Commissioner of Income-tax (Appeals), i. e., 30 per cent. of the purchases on estimated basis was upheld. 7. Facts of the earlier assessment year also show that estimation was made in respect of purchases from same party which was subsequently reduced to 25 per cent. while giv ..... X X X X Extracts X X X X X X X X Extracts X X X X
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