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2025 (4) TMI 2104

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....VIKAS AWASTHY, JM: This appeal by the assessee is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as 'the CIT(A)') dated 29.12.2023, for assessment year 2018-19. 2. The limited issued in this appeal is with regard to addition of Rs. 14,11,500/- u/s. 69A of the Income Tax Act, 1961(hereinafter referred....

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.... the gifts. 4. Per contra, Shri Sanjay Kumar representing the department vehemently defended the impugned order. The ld. DR submits that the assessee has placed on record return of income of her father and husband. The gifts made by father and husband are much more than the income returned by them in their respective returns. Whereas, no return of income of mother of the assessee was filed. The....

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....9, it is evident that capacity to make gift to the extent claimed by assessee is implausible. However, the explanation furnished by the assessee cannot be entirely brushed aside since parents of assessee and husband of assessee have confirmed the gifts. The possibility of such gifts from accumulated savings cannot be ruled out, completely. Taking into account entire facts of the case, and keeping ....