ORDER

PER RAVISH SOOD, JM:

The present appeal filed by the assessee is directed against the order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, dated 19/05/2025, which in turn arises from the order passed by the Assessing Officer (for short, “AO”) under section 147 r.w.s 144 r.w.s 144B of the Income Tax Act, 1961 (for short, “the Act”), dated 13/02/2024 for the Assessment Year (AY) 2018-19. The assessee has assailed the impugned order of the CIT(A) on the following grounds of appeal:

1. “The learned Commissioner ought to have appreciated that the assessee along with her reply denying that deposits in the Bank, submitted an Affidavit confirming the facts stated in the letter, denying the transactions as her business transactions, therefore, without disproving the contents of the Affidavit the learned Commissioner erred in sustaining the order of the Assessing Officer, wherein, the transactions of the firm (Petrolbunk) are treated as the turnover of the assessee to estimate the income at Rs.21,70,582/-.

2. The learned Commissioner ought to have appreciated that merely mentioning the assessees PAN in the Bank account of the firm will not becom