2. The assessee’s identical sole grievance canvassed in these two appeals seeks to reverse both the lower authorities adding the alleged undisclosed income of 17,88,666/- and 16,53,772/- respectively. Learned counsel’s only grievance during the course of hearing is that the assessee is a salaried person who was sold her stock holding in shares in the relevant two previous years. Mr. Tiwari also sought to emphasise that assessee has filed all necessary evidence before the lower authorities as well. The Revenue’s case on the other hand is that the impugned sums have been ITA No.1790-91/Kol/2019 A.Ys.2014-15 & 2015-16 Neha Chowdhary Vs. ITO Wd-46(3), Kol. Page 2 rightly treated as unexplained income since assessee could not prove source thereof during the course of scrutiny as well as in the lower appellate proceedings.

3. I have heard rival contentions against and in support of both the parties. It emerges that from a perusal of these case files that although the assessee has produced her documentary evidence before the lower authorities about the impugned sums to be in the nature of income derived from the sales of shares, the fact remains that her detailed explanation tendered in the course of assessment till date does not sufficiently discharg her onus on proving the source of impugned deposits. I therefore deem it appropriate in these peculiar facts and circumstances that the impugned addition(s) of 17,88,666/- and 16,53,772/- deserved to be restricted to that @ 30% only with a rider that same shall not be treated as a precedent in any other assessment year. The assessee gets part relief accordingly. Necessary computation to follow as per law.