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TMI Blog2012 (3) TMI 554X X X X Extracts X X X X X X X X Extracts X X X X ..... for the assessment years 2000-2001 and 2003-2004 are directed against the orders of the Ld CIT(A)-V, Surat. These are being disposed of with this common order for the sake of convenience. 2. At the time of hearing none appeared on behalf of the assessee. Accordingly, the appeals of the assessee are being disposed of exparte qua the assessee-appellant on merit after hearing the learned DR. ITA No ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al love and affection. Explanation filed in this regard by the assessee was rejected by the AO on the ground that the credit-worthiness of the donor could not be proved by the assessee. The assessee has a very close-relation with the donor as that of father and daughter and the natural love and affection could not be doubted by the Revenue in the case of the assessee. In this case, the assessee ha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f penalty under Section 271(1)(c) of the Act which is accordingly cancelled and the grounds of the appeal of the assessee are allowed. ITA No.1173/Ahd/2009 (A.Y.2003-2004) 5. The only issue in this appeal is regarding validity of penalty levied under Section 271(1)(c) of the Act amounting to Rs. 95,650/-. 6. The learned DR submitted that the assessee could not prove the genuineness and credit- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t-worthiness of the donors, it does not justify the imposition of the penalty under Section 271(1)(c) of the Act. The facts of the case may justify the additions of the gift amounts for taxation purpose in the assessment of the assessee, but are not sufficient to justify the imposition of the penalty under Section 271(1)(c) of the Act. We are unable to sustain the observations of the CIT(A) that t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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