Section 271(1)(c) Penalty Cannot Survive When Quantum Addition is Remanded

Nidhiben Mrugeshkumar Shah Vs ACIT (ITAT Ahmedabad)

Penalty u/s 271(1)(c) Cannot Survive When Quantum Addition is Remanded – Matter Restored to CIT(A)

Penalty u/s 271(1)(c) was levied on addition of ₹10,00,100 as unexplained cash deposits, &  minimum penalty of ₹1,55,561 was confirmed by CIT(A).

Before ITAT, Assessee submitted that the quantum addition itself had been remanded back by ITAT in ITA No. 990/Ahd/2025 (order dated 24.09.2025) because the lower authorities did not properly consider evidence explaining the source of cash. ITAT had directed CIT(A)

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