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TMI Blog2025 (2) TMI 830X X X X Extracts X X X X X X X X Extracts X X X X ..... bed in such bogus purchases HELD THAT:- The undisputed fact is that the additions were made on account of bogus purchases and the quarrel travelled up to the Tribunal and the Tribunal restricted the quantum addition at 12.5% of the bogus purchases. No merit in the contention of the ld. Counsel that the profit has been estimated and the penalty has been levied on estimated profit. Facts on record ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng the levy of penalty u/s 271(1)(c) of the Act amounting to Rs. 1,84,771/- on alleged estimated profits on the addition of unverified purchases. The roots of the levy of penalty lie in the assessment order dated 30/03/2015 framed u/s 143(3) r.w.s. 147 of the Act wherein, during the course of the scrutiny assessment proceedings, on the basis of the information received from the Sales-tax authoriti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d the judgment of the Hon'ble Supreme Court in the case of Reliance Petro Products Pvt. Ltd. (2010) 322 ITR (SC). It is the say of the ld. Counsel that considering several precedents, penalty should not be levied for the impugned estimated addition. 5. Per contra, the ld. D/R pointed out that no estimation was made. The AO added the entire bogus purchases whereas the Tribunal restricted the addit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... xtent in the garb of purchases which turned out to be bogus. Therefore, considering the facts of the case in totality, we have no hesitation in confirming the penalty so levied u/s 271(1)(c) of the Act. Accordingly, the effective ground/s raised by the assessee are dismissed. 7. In the result, the appeal of the assessee is dismissed. Order pronounced in the Court on 19th February, 2025 at Mumbai ..... X X X X Extracts X X X X X X X X Extracts X X X X
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