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JUDGMENT Vibhu Bakhru, J. - The present appeals have been filed on behalf of the Revenue under section 260A of the Income-tax Act, 1961 (hereinafter referred to as "the Act"). In I. T. A. No. 1095 of 2011, the Revenue has impugned a common order dated March 11, 2011, passed by the Income-tax Appellate Tribunal (hereinafter referred to as "the Tribunal") in I. T. A. No. 1409/Del/2009 and I. T. A. No. 2112/Del/2009. By way of I. T. A. No. 444 of 2012, the Revenue has assailed the decision of the Tribunal dated March 23, 2012, whereby its appeal against an order dated June 8, 2011, passed by the Commissioner of Income-tax (Appeals) setting aside a penalty of Rs. 18,52,435 imposed by the Assessing Officer under section 271(1)(c) of the Act, had been rejected. Both the appeals relate to the assessment year 2005-06 and the same have been taken up for hearing together. 2. The controversy in the present appeals relate to an addition of deemed income of Rs. 55,00,000 under section 69B of the Act as unexplained investment and levy of penalty as a consequence thereof. 3. Briefly stated, the relevant facts of the case are as under : 3.1 The assessee purchased a built-up property admeasuring 250 sq. metres bearing the address FD-22, Pitampura, Delhi. The conveyance deed of the property was registered and disclosed a consideration of Rs. 20 lakhs for the transaction. The said amount of Rs. 20 lakhs was paid by the assessee to the vendor, Ms. Poonam Chaudhary, by a cheque. The income-tax return for the assessment year 2005-06 was filed by the assessee on July 31, 2005, and was processed under section 143(1) of the Act, on February 23, 2006. In the meantime, the Investigation Wing of the Income-tax Department suspected that the transaction for sale and purchase of the property in question had not been correctly reflected and, accordingly, issued summons to the assessee under section 131 of the Act. The assessee appeared before income-tax authorities on November 18, 2005, and recorded his statement. Questions Nos. 11 and 12 posed and the answers recorded by the assessee are relevant and are quoted below : "Question No. 11 : Which property did you sell or purchase this year,…

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