2023 (10) TMI 1016

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....JM: The appeal has been preferred by the Revenue against the order dated 31.03.2019 of CIT(A)-3, Gurgaon (hereinafter referred as Ld. First Appellate Authority or in short Ld. 'FAA') in Appeal No. 418/ CIT(A)-3/GGN/2016-17 arising out of an appeal before it against the order dated 30.01.2018 passed u/s 271AAA of the Income Tax Act, 1961 (hereinafter referred as 'the Act') by the DCIT, Central Cir....

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.... income of Rs. 44 crores as income from other sources. Accordingly, issued notice u/s 271AAA of the Act. Ld. AO was not satisfied with the explanation of source and manner of earning the income concluded that assessee has not been able to substantiate the same for the purpose of Section 271AAA and imposed the penalty. Ld. CIT(A) has deleted the same on the basis of fact that in the quantum appeal,....

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....of Income Tax Investigation is in continuation of search and duly accepted by Revenue. The JDIT (Inv.) has not raised any objection about the nature of income disclosed by the assessee. The Assessing Officer and Ld. CIT(Appeals) have not brought any material on record to substantiate that the assessee has earned any income from other sources. This is admitted fact that the assessee is eligible for....