Held that the assessee had submitted the quantitative details of purchases with stock register entry and corresponding export sales which were also verified from the customer appraisal report. Source of payment of purchases had been made through books of account and account payee cheques and there were corresponding sales. Merely because an ad hoc gross profit rate had been applied on alleged bogus purchases to factor in suppression of alleged gross profit, penalty was levied under both the limbs, i. e., for furnishing of inaccurate particulars of income or concealing particulars of income. This showed that his satisfaction was vague. Accordingly, penalty levied on ad hoc estimate could not be sustained and  deleted.(AY.2007-08)