2026 (3) TMI 813

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....ed as 'the Act']. 2. The assessee has raised the following grounds of appeal : 1. Under the facts and circumstances of the case, Ld. CIT(A) has erred in sustaining the penalty imposed by the AO, u/s. 272A(1)(d) of the Act vide his order u/s. 250 dated 4.9.2025, which is unjust and unwarranted. 2. Under the facts and circumstances of the case, Ld. CIT(A) has erred in not considering the written submission regarding reasonable and bonafide cause filed by the appellant on 19.8.2025 in a right prospective. 3. Under the facts and circumstances of the case, the Ld. CIT(A) did not consider the facts that being an illiterate person farmer, ill health, the appellant did not response the statutory notices as he was not a....

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....00/-, and did not file any explanation regarding purchase of foreign currency and its source for aggregating the amount of Rs. 11,00,000/-. Therefore, the AO has added the amount of Rs. 56,99,500/- u/s. 69A r.w.s. 115BBE of the Act as unexplained money in the hands of the assessee. Subsequently, the AO has initiated penalty u/s. 272A(1)(d) for noncompliance of the statutory notice u/s. 142(1) and issued show cause notices. The assessee has not submitted any submission also during penalty proceedings. Hence, the AO proceeded to levy penalty u/s. 272A(1)(d) of the Act and levied penalty of Rs. 40,000/-. Against the same, assessee preferred an appeal before the Ld. CIT(A), who vide his impugned order dated 4.9.2025 dismissed the appeal of the ....