Sanjeev Kumar Goyal Vs ITO (ITAT Delhi)
The case of Sanjeev Kumar Goyal versus the Income Tax Officer (ITO) before the Income Tax Appellate Tribunal (ITAT) Delhi pertains to the assessment year 2013-14 and concerns the imposition of a penalty under Section 271(1)(c) of the Income Tax Act. The appeal was filed by the assessee against the order of the Commissioner of Income Tax (Appeals) [CIT(A)] confirming the penalty.
The grounds of appeal raised by the assessee primarily revolved around contesting the imposition of penalty and asserting that all additions made in the assessment order were on an estimate basis. They argued that the penalty was unjustified as the Assessing Officer (AO) did not specify the default for which the penalty was initiated.
The assessee, engaged in trading and manufacturing of timber products and firewood, filed their return initially declaring income of Rs. 4,82,499, which was later revised to Rs. 6,34,500. During scrutiny, the AO found discrepancies in turnover percentages between the original and revised returns and requested the assessee to substantiate trading results and income. Due to the absence of adequate documentation, the AO disallowed 10% of total expenses on an ad hoc basis and added it to the income of the assessee. Subsequently, penalty proceedings were initiated under Section 271(1)(c) for concealing income.
