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2020 (5) TMI 510 - AT - Income TaxAddition showing excess agricultural income of production of kismis - assessee did not furnish any evidence of carrying out agricultural operation - AO has computed total income from sale of kismis after taking highest rate of ₹ 60 per kg reported by the Director, National Research Centre for Grapes, Pune and difference was treated as income earned from undisclosed sources - HELD THAT:- Neither the assessee has given the break up and supporting detail of different varieties and quantities of kismis produced and sold during the year at different rates and nor the assessing officer has given the detail of kind of varieties to which the rates in the range of ₹ 55 to 60 per k.g are to be applied. In view of the facts and circumstances, we observed that it will be appropriate to take average of the rate as per the rate quoted by the assessee and average rate adopted by the assessing officer at ₹ 67 per kg. (₹ 76 + ₹ 58). After taking average of rate adopted by the assessee and average rate adopted by assessing officer at ₹ 67 per kg the total income from sale of ₹ 28,370 kg of kismis is determined at ₹ 1900790/- (28370 x67) as against sale price of kismis adopted by the assessee at ₹ 21,59,111/-, therefore, we restrict the disallowance to the extent of ₹ 2,58,321/- as against disallowance of ₹ 4,56,911/-made by the assessing officer. - Decided partly in favour of assessee.
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