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2024 (5) TMI 1021 - ITAT BANGALOREUnexplained money u/s. 69A - deposits in bank account during demonetisation period - as per DR assessee was unable to produce external evidence in support of agricultural income shown - HELD THAT:- We note that average agricultural income reported by assessee for previous three years is Rs. 3,87,667/-. We further note from the computation sheet of the AO that while computing total income the AO has himself accepted it as agricultural income and added. Once the AO has accepted agricultural income during the course of computing tax which is essential part of raising demand u/s 156 for completing the assessment, then the AO cannot treat it as unexplained investment u/s. 69A. Accordingly we accept the plea of the assessee that income should be considered as agricultural income and apply normal tax rate as applicable. Since in this case the assessee had shown agriculture income of Rs. 15,84,000/- in his return of income out of which a sum of Rs. 7.00 Lakhs has been accepted by the ld. CIT (A) treating it as agriculture income. The balance amount of Rs, 8,84,000/- is also to be considered as agriculture income as per our above observations. Assessee appeal allowed.
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