TMI Blog2022 (6) TMI 736X X X X Extracts X X X X X X X X Extracts X X X X ..... en by the above said concern. It was submitted by Ld. AR that the assessee is a non-resident and he did not visit India during the year under consideration. Since he has sold coffee seeds prior to the date of demonetization, he was constrained to deposit the cash into the bank account after announcement of demonetization. Hence the Ld. A.R contended that there is no reason to reject the explanations given by the assessee. Also merit in the submission made by Ld. AR. Since the evidence furnished by the assessee with regard to sale of coffee seeds has been confirmed by the purchaser, there is no reason to suspect the explanation given by the assessee - AO has not brought on record any other material to disbelieve the explanation so given b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssessee has claimed to have sold the coffee seeds after 2 years after the sale of agricultural land. The AO also issued notice under section 133(6) of the Act to M/s. Raj Coffee Curing Works, but did not receive any reply before the completion of assessment. Hence, the AO disbelieved the claim of sale of coffee seeds and accordingly assessed amount of Rs. 15 lakhs under section 69 of the Act. The Ld. CIT(A) also confirmed the same. Hence, the assessee has filed this appeal before the Tribunal. 3. The Ld. AR submitted that the assessee has made a detailed submissions with regard to the sources for making the impugned deposits before the AO and also furnished the purchase bills issued by M/s. Raj Coffee Curing Works in support of his claim ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had sold the agricultural land in the Financial Year 2013-14 and it is unlikely that the assessee has kept the coffee seeds with him for more than one year. Hence the explanation given by the assessee defies logic. He further submitted that the decision rendered by Hon'ble Supreme Court in the case of P K Noor Jahan cannot be applied in the facts of the present case, as the explanation given by the assessee defies logic. Accordingly, the Ld. D.R submitted that, in the absence of proper explanation about sources, the addition made by AO should be sustained. In this regard, he placed reliance on the decision rendered by Hon'ble Punjab and Haryana High Court in the case of Pavittar Singh Vs. CIT (2016) 282 CTR 285. 5. I heard the ri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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