TMI Blog2014 (7) TMI 873X X X X Extracts X X X X X X X X Extracts X X X X ..... hile working out non-agricultural income in the hands of the assessee, addition/disallowance in the hands of the assessee on account of non-agricultural income is not justified, as the conversion of raw seeds into pea seeds cannot be held as non-agricultural merely on the ground that there was a complete change from raw seeds into pea seeds which was not justified that the assessee changed such ra ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he processing of raw peas into pea seeds is a process ordinarily employed by the cultivator within the meaning of Section 2(1A)(b)(ii) or 2(1A)(b)(iii) in spite of the admission of the assessee in his statement on oath dated 28.02.2000 that there was Hindustan Lever Canning Plant which provides ready market for raw peas? (ii)Whether the Hon'ble ITAT has erred in holding that the assessee on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... profits? 2. Learned counsel for the revenue has very fairly conceded that issue raised in the present appeal is identical to one raised in ITA No. 396 of 2005 decided on 03.02.2011. It was submitted by the learned counsel for the revenue that the Tribunal had also relied upon its earlier order, which was under challenge in that appeal. It was further submitted that all the questions have been ..... X X X X Extracts X X X X X X X X Extracts X X X X
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