2025 (9) TMI 1432

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....n 147 of the Income Tax Act, 1961 (hereinafter referred to as the "Act"), the other appeal lies against order of the Ld. CIT(A) confirming the levy of penalty under Section 271(1)(c) of the Act on the addition made to the income of the assessee in the quantum proceedings. 2. Issues involved in both the appeals being interrelated they were taken up together for hearing and are being disposed of by this common order for the sake of convenience. 3. I shall first deal with the assessee's appeal in quantum proceedings in ITA No.958/Ahd/2025. 4. At the outset, Ld. Counsel for the assessee pointed out that the solitary issue in the present appeal relates to addition made to the income of the assessee on account of cash found deposited in ....

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....s been used to pay for credit card dues of her son who was studying abroad. The assessee's contention, therefore, are that the cash deposited in her bank account in no way represent her income, appears to be plausible explanation. Even, the Revenue has failed to unearth any activity being carried out by her to justify the earning the quantum of cash which is found deposited in her bank account. So far as per explanation of the same being given to her by her husband and brother, we have noted that though she has attempted to justify the same by filing confirmation of her husband and brother. The Ld. CIT(A) has noted the confirmation of loan received by her husband to be signed by herself while that received from her brother, he has noted the....