Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)
Condonation of Errors and Relief on Merits in Interest of Justice The penalty is based on an addition which itself was challenged. The appellant made written submissions (albeit late), and attempted to explain the nature of deposits and his commission business. Even assuming the income was assessable, the profit element cannot be the entire gross deposit. The penalty on such