Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2021 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2021 (9) TMI 640 - AT - Income TaxReopening of assessment u/s 147 - Unexplained investment made in one piece of land - Proceedings initiated U/s. 147 of the Act was upheld by the ld. CIT(A) on the ground that the assessee failed to explain the source - AO only disputed the sales bills was not produce by the assessee - HELD THAT:- It is a true fact that the assessee is having 60 Bigha of land. This fact is also accepted by the Assessing Officer in the assessment order that assessee produced Jamabandi and Girdawari only but no bill of agriculture produced/crop were produced. The A.O. only disputed the sales bills was not produce by the assessee. This objection of the A.O. was not correct because in the rural area the crops was sales in village and sometime crops sales in Mandi but bills was not kept by the farmers. CIT(A) had given relief of ₹ 2,00,000/- to the assessee on the basis of documents and material placed on record. The ld. CIT(A) has passed a speaking order discussing all the facts and circumstances of the case. No new facts has been brought on record by the ld. CIT(A), therefore, considering the totality of facts and circumstances of the case, we do not find any reason to interfere or deviate from the findings so recorded by the ld. CIT(A), hence, we uphold the same. Appeal dismissed.
|