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2021 (2) TMI 35 - HC - Income TaxReceipt or accrual of any real income - Agricultural income - income returned as 'income from other sources' which are unexplained - HELD THAT:- As submitted that from perusal of the agreement it is clear that the land is earmark for growing / developing of land for different crops and no trees of any kind were found on the land prior to execution of the lease agreement. It has further been found that the buildings or animal sheds were not constructed on the lands which was leased out to the assessee as the possession of the land in question was never handed over to the assessee. Similarly, the tribunal has recorded the finding that the assessee was neither in possession of the agricultural land nor he performed any agricultural activity. Therefore, the question of earning any agricultural income does not arise. The aforesaid findings are pure findings of facts which have been recorded on meticulous appreciation of evidence on record. The aforesaid findings have not been shown to be perverse. It is well settled that this court in exercise of powers under Section 260A of the Act cannot interfere with the finding of fact until and unless the same is demonstrated to be perverse. [See: SYEDA RAHIMUNNISA VS. MALAN BI BY L.RS. AND ORS. [2016 (10) TMI 1233 - SUPREME COURT] and PRINCIPAL COMMISSIONER OF INCOME TAX, BANGALORE & ORS. VS. SOFTBRANDS INDIA P. LTD [2018 (6) TMI 1327 - KARNATAKA HIGH COURT]] In view of preceding analysis, the substantial questions of law are answered accordingly.
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