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TMI Blog2022 (2) TMI 981X X X X Extracts X X X X X X X X Extracts X X X X ..... ome. But at no point of time, the assessee with any documents before the AO or before the CIT(A) or before us has shown that the assessee was actually having agricultural income. This shows that the assessee was not having the genuine agricultural income. Mere oral submissions or indication that evidences will be provided if revenue asked at later stage shows that the assessee was not at all dispensed the burden of proving his claim that the said income and expenses were part of agricultural income. As regards the explanation for the personal account and its maintenance, the Ld. A.R. has not set out any case as to why said practice was followed by the assessee. The assessee was not at all maintaining proper books of accounts. Thus, groun ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ) The learned CIT(A) has erred in law and on facts of the case in confirming action of the ld. AO in initiating penalty u/s. 271(1)(c) of the Act. 3. The assessee filed return of income declaring income of ₹ 51,18,760/- on 28.09.2013. The assessee's case was selected for scrutiny and the statutory notice under Section 143(2) of the Income Tax Act, 1961 was issued on 03.09.2014. In response to the notices, the Authorized Representative of the assessee appeared before the Assessing Officer and submitted the details. The Assessing Officer observed that the assessee introduced fresh capital in cash during the year under consideration for which the assessee claimed that an amount of ₹ 12,00,000/- was introduced on account of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inadvertently. The Ld. A.R. further submitted that so far as receipts of proceeds on account of agricultural activities are concerned, the assessee prayed before the CIT(A) that the same will be submitted during the remand proceedings as and when required. As regards rental income, the assessee has not pressed ground No. 2. 6. The Ld. D.R. relied upon the Assessment Order and the order of the CIT(A). 7. We have heard both the parties and perused all the relevant material available on record. It is pertinent to note that the assessee has not filed any details regarding the agricultural income and the expenses incurred which is an admitted position as the assessee made submission before the CIT(A) while filing additional evidence that t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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