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TMI Blog2020 (7) TMI 723X X X X Extracts X X X X X X X X Extracts X X X X ..... sted by Ms.K.G.Usharani, SC For Respondent: Mr.R.Sivaraman COMMON JUDGMENT (Judgment was delivered by T .S.Sivagnanam,J) We have heard Mr. T.R. Senthilkumar, learned Senior Standing Counsel assisted by Ms.K.G.Usharani, learned Standing Counsel appearing for the appellant - Revenue and Mr. R. Sivaraman, learned counsel appearing for the respondent - assessee. 2. These appeals, filed by the Rev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e facts and circumstances of the case, the Tribunal can estimate the agricultural income without there being any proof that the assessee was actually engaged in agricultural activity and the onus to prove the same was agricultural income lies on the assessee? 3. Whether on the facts and circumstances of the case, the Tribunal was right in presuming that the agricultural income based on the land ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee? 3. Whether on the facts and circumstances of the case, the Tribunal was right in presuming that the agricultural income based on the land holding of the assessee including lease hold lands on the oral contracts with the lessees even though the assessee failed to produce any evidence in support of such a claim for its agricultural activities? 4. Whether on the facts and circumstances of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ax effect is lower than the threshold limit, the Revenue may be permitted to pursue the matters together so that in the event of the Revenue succeeding in the appeals, the exchequer will be able to recover tax. 5. In our considered view, the proper interpretation of the circular issued by the Central Board of Direct Taxes is that if the tax effect is lower than the threshold limit, the Revenue ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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