2025 (10) TMI 903

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....me-tax Act, 1961 (for short 'the Act') was issued on the assessee through Speed Post after obtaining approval from ld. Pr. CIT, Meerut. Since there was no response from the assessee, notices u/s 142(1) along with questionnaire were issued to the assessee. Since there was no compliance to the various invoices issued to the assessee, the assessment was completed u/s 144/147 of the Act. The AO received information from office of CIB/AIR with regard to cash deposit exceeding Rs. 10 lakhs in the same bank account during the FY 2009-10 in PAN No.AAFPZ1420J. In order to verify the same, notice u/s 133(6) was issued to Axis Bank, Meerut Branch and as per the information, the assessee has deposited cash to the extent of Rs. 19,35,000/- in his bank a....

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....o compliance from the assessee. Since the assessee failed to make use of these opportunities, ld. CIT (A) dismissed the grounds raised by the assessee. 5. Aggrieved assessee is in appeal before us raising following grounds of appeal :- "1. That the appellate order has not been received by the assessee till date. The Appeal is being filed by downloading the copy of order from assessee's Income Tax Portal. 2. That the Ld.CIT(A) has erred in confirming upholding the penalty of Rs. 1,09,600/- imposed u/s 271(1)(c) by the AO, which being tenable and unjustified under the facts and circumstances of the case be kindly cancelled. The assessee - appellant is far more aggrieved by the colourable manner in which the a....

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.... 31-03-2018 i.e. in next Financial Year." 6. At the time of hearing, ld. AR of the assessee submitted the relevant facts on record and submitted that it is a joint account maintained by the assessee along with family members. The AO initially proposed addition of Rs. 19,35,000/- and ld. CIT (A) has reduced the same considering the factual matrix on record and sustained the addition to the extent of peak credit. He further submitted that the similar addition was also made in the hands of the wife of the assessee and the same was allowed in favour of assessee's wife. He prayed that the penalty imposed by the AO is not maintainable. 7. On the other hand, ld. DR of the Revenue relied on the findings of the lower authorities. 8. Conside....