Reply for notice u/s 271(1)(c) for bogus purchase

This query is : Resolved 

23 February 2019 One of my client has been served by notice u/s 271(1)(c) for the addition because of bogus purchase, assessee has gone for appeal l so and order has been passed and 95% of addition was cancelled still assessee received notice. I am searching for judgement in support of non payment of penalty . kindly suggest me any relevant case laws which I can attach along with summary in the reply of such notice


24 February 2019 Identical case law (95:5) seems not available. Since 95% is left out, plead for non
levy on the remaining 5%


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