2023 (5) TMI 152

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..... and corresponding sales had not been doubted. The sources of purchases are from the books and overall trading results have been accepted. Only allegation is that assessee has taken accommodation bills for the purchase of items to suppress the profits. Once, the addition has been made on adhoc and estimate which has been reduced by the Tribunal, then it cannot be held that there is any concealme .....

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..... by way of the consolidated order. In all the year the penalty has been levied on account of adhoc addition of GP rate on bogus purchases. 2. In the assessment order, the addition have been made by the AO on the basis of certain information received from Sales Tax authorities that assessee had made purchases from various suspicious parties. The Assessing Officer accordingly applied GP rate on a .....

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..... egation is that assessee has taken accommodation bills for the purchase of items to suppress the profits. Once, the addition has been made on adhoc and estimate which has been reduced by the Tribunal, then it cannot be held that there is any concealment of income so as to warrant any penalty u/s 271(1)(c), Accordingly, on merits the penalty is deleted. 3. In AY 2009-10 the Ld. Counsel submitted .....

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