2024 (3) TMI 1070

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....Sr.DR ORDER PER PRADIP KUMAR KEDIA-AM: The captioned appeal has been filed by the assessee against the order of the Commissioner of Income Tax (Appeals)-II, Gurgaon ('CIT(A)' in short) dated 28.05.2019 in relation to the penalty order dated 31.03.2018 under Section 271(1)(c) of the Income Tax Act, 1961 (the Act) concerning AY 2013-14. 2. The solitary issue in the captioned appeal is justificat....

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....e matter of record that copy of ITR acknowledgement of uncle showing cash withdrawals in their account and corresponding deposit in the bank account of assessee was furnished. The ld. counsel submits that the mother of the deceased-assessee is not taxable since she is a farmer and the amount received on sale of agricultural land a part of which was given to assessee whereas the uncle of the assess....

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....tent stand towards source of cash deposits from his uncle and mother. The bank statement vouches for withdrawal of cash in the hands of relatives. The assessee thus has offered explanation in respect of source of cash deposit which may not have been accepted for the purposes of quantum proceedings but sustaining such addition in the quantum proceedings could not, in our view, warrant a conclusion ....