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TMI Blog2024 (2) TMI 1047X X X X Extracts X X X X X X X X Extracts X X X X ..... le consideration from the proceeds of sale of agricultural land was duly disclosed in the statement of income read with the schedule thereto. As regards the interest income from Axis Bank, the same is also duly disclosed in the entry relating to TDS under the head 'Total income' read with Schedule 18. Thus, it appears that the AO did not take into account the material placed on record and, consequently, the order impugned herein is vitiated by non-application of mind. Addition of loan availed of by the petitioner it appears that the petitioner has not placed all necessary documents on record. Therefore, it is just and necessary to direct the petitioner to place all relevant documents for consideration. For reasons set out abov ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bmits that the opening balance for the relevant year, as per the ledger account, was a sum of Rs. 4,15,43,048.75. The closing balance was Rs. 19,56,49,669.49. By referring to paragraph-8 of the affidavit, he submits that this difference was duly explained. With specific reference to the sale of agricultural land for the total consideration of Rs. 7,91,00,000/-, learned counsel submits that this was duly disclosed. In this connection, he refers to the statement of income which was annexed to the revised return of income. He points out that the entire sale consideration was reflected and that the details thereof are set out under the heading 'income with full exemption'. 4. As regards the third addition of a sum of Rs. 2,10,000/-, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g counsel contends that the sum of Rs. 2,40,000/- was liable to be added to the income. As regards the transaction relating to the sale of agricultural land, he submits that the petitioner did not place all relevant documents on record to establish that the income was duly disclosed and that such income is exempt from income-tax. 6. On examining the impugned assessment order, it appears that the aggregate additional income was arrived at by examining the difference between the opening and closing balance. While undertaking this exercise, the respondent has failed to take into account the fact that the sale consideration of Rs. 7,91,00,000/- from the proceeds of sale of agricultural land was duly disclosed in the statement of income read ..... X X X X Extracts X X X X X X X X Extracts X X X X
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