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2022 (3) TMI 1571 - KERALA HIGH COURTAssessment u/s 153A r.w/s 153C - validity of documents found during search - HELD THAT:- After appreciating the materials, referring to which proceedings under Section 153A r.w.s. 153C have been initiated, we find it difficult to appreciate how the assessee can object to the instant enquiry, mainly initiated by reference to documents recovered in the search. We express our agreement with the view expressed by the CIT (Appeals) and the Tribunal., which are again based on the documents seized, and the connection the said documents establish with the assessee. The questions are answered in favour of the Revenue and against the assessee. Nature of income - rejecting the claim of agricultural income and treating the income as income from other sources - HELD THAT:- This Court, in the appeals filed by the assessee’s husband [2018 (4) TMI 1969 - ITAT COCHIN] considered the claim of all the assesses subjected to reopening of assessment upon search and seizure. The case of the assessee, for agricultural income, is from two sources of agricultural income. The finding recorded by the Commissioner is that nothing is forthcoming for accepting the agriculture income. Though a general ground is raised, in our considered view , after perusing the findings recorded by all the authorities under the Act on this behalf, we are satisfied that substantial questions do not arise, and we affirm the findings recorded on this behalf. Hence, the questions are answered in favour of the Revenue and against the assessee.
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