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2025 (12) TMI 25

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...., Sr. DR ORDER The present appeal has been preferred by the assessee against the order dated 11.10.2024 of the Commissioner of Income Tax (Appeals) NFAC, Delhi [in short 'the CIT (Appeals)] pertaining to 2009-10 assessment year. 2. The assessee in this appeal is aggrieved by the action of CIT (Appeals) in confirming the penalty levied by the Assessing Officer (in short 'the AO') u/s 271D ....

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....nk account, therefore, the said amount of Rs. 20 lacs was deposited by him into the account of the assessee for a short duration, only for the purpose of safety and security. That the amount was withdrawn and paid back to him just after 5 days of the deposit. It was, therefore, submitted that the aforesaid deposit of Rs. 20 lacs into the account of the assessee was not any loan or deposit and henc....