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2019 (11) TMI 200 - AT - Income TaxAddition u/s 69A r.w.s. 115BBE - A.O. proceeded to estimate the agricultural income by taking into consideration the total land holdings of the assessee and approximate crop yield - A.O. has estimated agricultural income partly and the balance amount was assessed as income of the assessee from undisclosed source - HELD THAT:- A.O. has not disputed the fact that the agricultural operations on the agricultural land measuring 30 acres in Hanumangarh were carried out by the tenant one Shri Mahendra Singh S/o Shri Mani Ram. In order to verify the fact, the A.O. examined the said person and recorded his statement. He has admitted the fact of agricultural activity carried out on the agricultural land of the assessee and payment of ₹ 19,60,000/- through cheques issued from OBC bank account. Once the payment of ₹ 19,60,000/- were admitted by the tiller/tenant who has carried out agricultural operations and that too through the banking channel then to that extent the agricultural income of the assessee for the year under consideration cannot be doubted. CIT(A) has accepted the source of deposit to the extent of ₹ 4,10,000/- as past savings of the assessee. Accordingly, by considering the said amount of ₹ 19,60,000/- as agricultural income for the year under consideration and ₹ 4,10,000/- as past savings of the assessee, the source of deposit to the extent of ₹ 23,70,000/- is accepted, as explained by the assessee. Hence, the addition of the remaining amount of ₹ 1,61,200/- is sustained. Appeal of the assessee is allowed in part.
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