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TMI Blog2022 (3) TMI 899X X X X Extracts X X X X X X X X Extracts X X X X ..... d on any incriminating/seized material found as a result of search. Even, the disallowance of loss claimed against house property income is also not with reference to any seized material. It is a fact on record that on the date of search, the assessment proceedings relating to the impugned assessment years did not abet As per the ratio laid down by the Hon ble Jurisdictional High Court in the c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Accountant Member For the Appellant : Sh. Sachin Jain, CA For the Respondent : Sh. Satpal Gulati, CIT(DR) ORDER PER SAKTIJIT DEY, JM: These appeals are filed by the same assessee and arise out of a common order dated 17.05.2017 passed by learned Commissioner of Income Tax (Appeals)-31, New Delhi, pertaining to assessment years 2007-08 to 2013-14. However, presently we are ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Consequent to search and seizure operation, proceedings under section 153A of the Act were initiated for the preceding six assessment years, including the assessment years under dispute in the present appeals. In response to notices, issued under section 153A of the Act, assessee filed his return of income offering additional income as well as agricultural income. While completing the assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (Appeals). 5. Having considered rival submissions and on perusal of the orders of the departmental authorities, more specifically, observations made by the Assessing Officer in the assessment orders, we are convinced that the addition of agricultural income as income from other sources was not based on any incriminating/seized material found as a result of search. Even, the disallowance of l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g Officer. Accordingly, we delete the addition/disallowance made on account of agricultural income and set off of loss against house property income. In view of our decision above, various other grounds raised by the assessee having become academic, are not adjudicated. 6. In the result, the appeals are allowed, as indicated above. Order pronounced in the open court on 17th March, 2022 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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