TMI Blog2022 (12) TMI 1379X X X X Extracts X X X X X X X X Extracts X X X X ..... to examine the evidences including sale invoices of agricultural produce and in the remand report, AO has partly accepted assessee s claim on sale of potato - He has rejected balance amount only because sale invoices were not produced by the assessee. The fact that the assessee has sold agricultural produce, cannot be disputed because, even, the departmental authorities have accepted a part of assessee s receipts from sale of agricultural produce. Only a part of amount claimed to have been received from sale of potato has been rejected due to alleged non-furnishing of evidence. When the assessee has established on record that it had receipts from sale of agricultural produce, only because some invoices relating to sale are not availab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n that in the year under consideration, the assessee had made investment of Rs.85,00,000 in purchasing of immoveable property, the Assessing Officer reopened the assessment under Section 147 of the Act. 6. In course of assessment proceedings, the assessee was called upon to explain the source of such investment. From the details furnished by the assessee, the Assessing Officer found that in the year under consideration, the assessee had purchased an agricultural land jointly with another person and made investment of Rs.45,78,550. He, therefore, called upon the assessee to explain the source of such investment. In response, the assessee submitted that he received loan of Rs.4,00,000 from his mother, Rs.3,00,000 from his brother and he re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ze and potato etc. However, in course of assessment proceedings, while the Assessing Officer accepted the withdrawals from bank and past savings, he rejected the claim of loan from mother and brother as well as part of agricultural income, claimed to have been received from sale of potato. However, he accepted that the assessee received some amount from the sale of crops like sugarcane and maize. 11. In course of first appellate proceedings, learned Commissioner (Appeals) had directed the Assessing Officer to examine the evidences including sale invoices of agricultural produce and in the remand report, the Assessing Officer has partly accepted assessee s claim on sale of potato, to the extent of Rs.10,36,305 out of Rs.24,00,000. He has ..... X X X X Extracts X X X X X X X X Extracts X X X X
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