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TMI Blog2020 (5) TMI 161X X X X Extracts X X X X X X X X Extracts X X X X ..... hing impossible one. So long as the agriculture activity in this country is un-organized and it is sold in the un-regulated market, no one could establish the agriculture income. Moreover, the investment is only 22.50 lakhs. In the present economic scenario, which prevails in our country even a small agricultural labour would earn ₹ 500 to ₹ 1,000/- in day. A person employed in hair ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e is directed against the order passed by the Commissioner of Income Tax (Appeals)-16, Chennai dated 12.02.2019 and pertains to the assessment year 2007-08. 2. Shri G. Baskar, the Ld. Representative for the assessee submitted that the only issue arising in this appeal is confirming the addition of ₹ 22,50,000/- u/s. 69B of the Income Tax Act, 1961 (in short the Act ). According to the Ld ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... have agricultural income from HUF to the extent of ₹ 8.50 lakhs. The assessee has received ₹ 6.50 lakhs from his wife from agricultural income. This explanation of the assessee was not accepted by the AO since there was a contradictory statement recorded u/s. 131(1A) of the Act. The assessee appears to have explained that the source for purchase of residential flat was from business an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he addition made by the AO. 4. Having heard the Ld. Representative for the assessee and the Ld. Departmental Representative, this Tribunal is of the considered opinion that the assessee has explained before the Assessing Officer, the source of deposit of ₹ 22.50 lakhs. The AO in fact reproduced the explanation of the assessee at para 6 of his order. Since, the AO doubts the genuineness of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n this country. Taking into consideration of the economic situation prevails in the country, this Tribunal is of the considered opinion that there is no justification for making addition of ₹ 22.50 lakhs. Accordingly, the orders of both the lower authorities are set aside and the addition of ₹ 22.50 lakhs is deleted. 5. In the result, the appeal filed by the assessee stands allowed. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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