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ITAT allowed the appeal and deleted the penalty imposed under s. 271(1)(c) on the assessee, holding that the AO erred by attributing joint-account cash deposits solely to the assessee without verifying receipts by other joint-account holders or confining additions to the extent of income declared by the assessee or deposits attributable to him. The Tribunal found the AO failed to make requisite enquiries into family-member deposits and proceeded to levy penalty without proper basis. The Tribunal also noted procedural prejudice: notices were not received by the assessee due to communications sent to an incorrect email ID. On these grounds the penalty was held unjustified and set aside.
ITAT allowed the appeal and deleted the penalty imposed under s. 271(1)(c) on the assessee, holding that the AO erred by attributing joint-account cash deposits solely to the assessee without verifying receipts by other joint-account holders or confining additions to the extent of income declared by the assessee or deposits attributable to him. The Tribunal found the AO failed to make requisite enquiries into family-member deposits and proceeded to levy penalty without proper basis. The Tribunal also noted procedural prejudice: notices were not received by the assessee due to communications sent to an incorrect email ID. On these grounds the penalty was held unjustified and set aside.
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