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Issues:
- Dispute over addition of Rs. 12,000 as income from other sources instead of agricultural income for the assessment year 1987-88. Analysis: 1. The Revenue appealed against the deletion of the Rs. 12,000 addition by the Dy. CIT(A), claiming it was income from agriculture. The AO had rejected the claim due to lack of evidence of land possession during the relevant year, making the addition as income from other sources. 2. The CIT(A) deleted the addition, leading to the Revenue's appeal before the Tribunal. The Revenue argued that the assessee failed to prove ownership of land, crops grown, and sale vouchers, supporting the income's agricultural nature. The authorized representative contended that the land was allotted permanently on 11th April, 1991, with prior temporary allotment to the assessee's father. The Department accepted the agricultural income of the assessee's brother in a subsequent assessment, supporting the family's agricultural activities. 3. The Tribunal found that the AO did not identify any assets representing the Rs. 12,000 income and did not investigate the utilization of the agricultural income. As no addition was made under s. 69C for unexplained expenditure, the deletion of the addition by the CIT(A) was considered justified. The Tribunal upheld the deletion based on the lack of assets representing the income, acceptance of agricultural income in subsequent years, and the family's history of agricultural land possession. 4. Considering the circumstances, the Tribunal declined to interfere with the CIT(A)'s decision, upholding the deletion of the Rs. 12,000 addition as income from other sources. The Revenue's appeal was dismissed, affirming the decision in favor of the assessee for the assessment year 1987-88.
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