2025 (2) TMI 1390

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.... the following grounds of appeal: "1) On facts and circumstances of the case, the Ld. A. O. and Hon. DRP is not justified in making aggregate addition of Rs. 13,60,000/- with respect to amounts received by the Appellant from her husband, her HUF and her father-in-Law and assessing the same U/s. 68 by holding the same as unexplained. The Ld. A. O. and Hon. DRP failed to appreciate that the Appellant substantiated the credits by proving the identity, genuineness and capacity of the payers. 2) Without prejudice to above, the addition of Rs. 13,60,000/- has been made U/s. 69A of the Income Tax Act despite the fact the draft assessment proposed the addition U/s. 68." 3. Brief facts of the case are that the assessee ....

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.... the Act. 7. Aggrieved with the order of AO, the assessee has preferred an appeal before the Tribunal. Before us, Ld. AR has submitted that during the course of remand proceedings, all the requisite details were submitted before the Ld. AO. These were largely accepted by the Ld. AO in his remand report submitted to the DRP. However, in its final direction Ld. DRP only allowed relief to the assessee with regard to Rs. 71,000/- received from her son Shri Kain Shah and the remaining amounts were treated as unexplained. Ld. AR has, further, submitted a paper book containing copies of documents furnished before the Ld. AO as well as Ld. DRP and argued that the onus on the assessee to prove the identity of the creditors, the genuineness of the....