TMI Blog2023 (1) TMI 1005X X X X Extracts X X X X X X X X Extracts X X X X ..... r is erroneous, prejudicial to the interest of Revenue as well. Lack of enquiry by the AO in the scrutiny proceedings - All the sale proceeds from the sale of agricultural produce were credited in the bank account of assessee and in support of which the assessee enclosed bank account in State Bank of India together with books of account. PCIT made no adverse remarks or reference to the reply submitted by the assessee in respect of transport expenses, proof of sale of agricultural produce and details of bank accounts. It is settled position that the PCIT mandated to give reasoning why the order of assessee is erroneous as well as prejudicial to the interest of Revenue. PCIT did not give any reasons for non-consideration of reply subm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the opinion that the assessee explained in assessment proceedings that he had derived agriculture income from sale of strawberry, various vegetables, mushroom and food grains, but however, the 7/12 extracts shows cultivation of crops like rice, nachani, vatana, grass and potato. Further, no costs were debited to the profit and loss account on sale of agricultural products. He issued show cause notice on the premise that the AO has failed to verify genuineness of cash in hand/sundry debtors as on 31-03-2016. In response to the said show cause notice, the assessee contended that all the details relating to agriculture income were furnished before the AO and on an examination of which by following earlier assessments which were conducted under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2013- 14, 2014-15, 2015-16, 2016-17 and 2017-18 were filed before the PCIT contending that the assessee was also awarded IWG/2021-Winner IWGA- 2020 Award for agriculture activities. Therefore, it is clear from the record the case of the assessee were selected for limited scrutiny finding huge agricultural income in the year under consideration and also in the earlier assessment years. On perusal of the assessment order dated 07-12-2018, it is noted that the AO asked the assessee to give details in respect of agricultural income and the assessee submitted details as called for by the AO. On reading of para 4 of the assessment order, it is clear the AO considered the submissions of assessee in respect of declaration of huge agricultural incom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... its own Mahindra Scorpio vehicle and sometimes goods were transported by ST parcel service. It is also contended that the respective Shopping Mall personnel used to pick up the agricultural goods from the assessee. It is also enclosed ledger extract from the books of account in the year under consideration, wherein, it is noted ledger extract received from assessee s customers were placed on record. However, that all the sale proceeds from the sale of agricultural produce were credited in the bank account of assessee and in support of which the assessee enclosed bank account in State Bank of India together with books of account. The PCIT made no adverse remarks or reference to the reply submitted by the assessee in respect of transport expe ..... X X X X Extracts X X X X X X X X Extracts X X X X
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