2025 (9) TMI 1363

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....13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2023-24/1056543340(1), dated 26.09.2023 involving proceedings under section 147 r.w.s. 144 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). 2. Heard both the parties at length. Case file perused. 3. It emerges ....

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.... same has been rightly made in the assessee's hands as she could not explain the source of her cash deposits. 6. I have given my thoughtful consideration to the assessee's and Revenue's foregoing vehement rival contentions and find no reason to express my consent to either party's stand in entirety. This is for the precise reason that although the assessee has been able to prima facie indicate ....