9911796707
TMI Blog2012 (6) TMI 155X X X X Extracts X X X X X X X X Extracts X X X X ..... at length. 3. Briefly stated, the facts of the case are that the assessee filed his return of income on 30.3.1992 for assessment year 1999- 2000, declaring total income of Rs. 22,000/-. A survey u/s 133A of the Act was conducted in the case of M/s T.S.Subramaniya Chettiar and Sons, Panrutti, on 17.9.1992. During this survey it was found that the assessee had availed loans from the above firm. Consequent upon this survey proceedings, the assessee's case was selected for scrutiny and assessment was completed on 23.9.1993 at a total income of Rs. 13,03,640/-. Aggrieved by the order of the Assessing Officer, the assessee went before the ld. CIT(A), who has deleted a portion of the addition and has remanded other portion of addition, fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... from individual account of Shri Mayakrishnan, who is the Kartha of the Assessee-HUF. This credit was introduced in the earlier assessment year and was not related to this assessment year. This fact was verified from the copy of trial balance of the earlier year and the claim of the assessee was found to be correct. In this regard also, no material argument was advanced from the side of the Revenue. Therefore, we cannot disturb this finding of the ld. CIT(A) and hence, this ground also stands dismissed. 7. During the course of survey, it was found that M/s T.S.Subramania Chettiar and Sons had advanced huge amounts outside the books of account, to various persons, including the Assessee-HUF. The assessee used to get huge sums by sign ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s an agriculturist and Shri M.Ravichandran was only an MBBS student. Smt.Neelavathy and her sons did not have any independent sources of their income, to make such huge investments. The sources for the above investment were not fully explained by the assessee. To explain the sources of investments made by the assessee amounting to Rs. 4,49,153/-, the assessee enclosed a trial balance as on 31.3.1990. The assessee claimed loan of Rs. 1,60,000/- in the credit side of the trial balance. The assessee filed confirmatory letters from two persons namely, Shri G.Rajagopal and Shri Deivasigamani. A sum of Rs. 60,000/- was claimed as credit from individual account of Shri Mayakrishnan. The Assessing Officer added these credits to the total income on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ammal 22-11-1989 Rs. 50,000 " 11. From the records it was noticed that there are landholdings in the name of Shri M.Ravichandran, as detailed below: Date of purchase Amount Property details 2.9.1978 11,200 1 acre 50 cents of lands at Melmampattuvillage 27.4.1983 694 11.1/4 cents of lands at Melmampattu village 17.11.1984 8,800 39 cents of lands at Chinnapurangani village 3.6.1986 27,327 2 acre 36 cents at Kadampuliyur 12.8.1987 38370 4 acre 30.1/2 cents of lands at Kadampuliyur 25.4.1988 14,716 31 cents of lands t Vadakailasam village 101106 12. In the absence of any evidence of agricultural income filed, the Assessing Officer has estimated net agricultural income at Rs. 31,750/-. Finally f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t source of income and deleted the addition made towards unexplained loan in the name of S.Subramania Chettiar and Sons amounting to Rs. 1,08,000/- stated as source for the investment mad by Smt. Neelavathi, which is contradictory. 8. The CIT(A) erred in deleting the addition of excess agricultural income of Rs. 37,150/- admitted b Smt. Neelavathi Ammal assessed in the hands of HUF since the assessee has not filed proper details and the highest agricultural income returned by the assessee herself for the earlier year itself is Rs. 18,110/-. 9. The CIT(A) erred in deleting the addition made towards interest and commission credit9d in the accounts of Smt. Neelavathi Ammal by Rs. 16,120/- in the hands of the assesse HUF, since ..... X X X X Extracts X X X X X X X X Extracts X X X X
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