TMI Blog2024 (5) TMI 1021X X X X Extracts X X X X X X X X Extracts X X X X ..... . Ghale, Standing Counsel ORDER PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER This appeal is filed by the assessee against the order dated 15.01.2024 of the CIT(Appeals), National Faceless Appeal Centre, Delhi [NFAC] for the AY 2017-18. 2. The brief facts of the case are that the assessee filed return of income on 30.7.2017 declaring total income of Rs. 8,64,980. The case was selected for scrutiny ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ement and was unable to explain the source. Accordingly this income was also treated as unexplained money u/s. 69 of the Act and assessment was completed. 3. Aggrieved, the assessee filed appeal before the CIT(Appeals) and submitted past three years income from agricultural activities and it was also not disputed that he assessee owns agricultural land and claimed to have mango garden on the said ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on cash deposits during the demonetisation period. Accordingly, he partly allowed the appeal of assessee. Aggrieved, the assessee filed appeal before the ITAT. 5. The ld. AR submitted that there is no dispute that the assessee is holding agricultural land and submitted that detailed sales receipts were submitted before the revenue authorities which was not accepted. The assessee has sold varieti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mitted that the main source of agriculture income if from sale of verities of mangos and which does not require recurring expenditure as compared to other crops like paddy, wheat, sugarcanes etc., CIT has wrongly observed that the income is 81%. 6. The ld. DR relied on the order of the lower authorities and submitted that assessee was unable to produce external evidence in support of agricultural ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... investment u/s. 69A. Accordingly we accept the plea of the assessee that income should be considered as agricultural income and apply normal tax rate as applicable. Since in this case the assessee had shown agriculture income of Rs. 15,84,000/- in his return of income out of which a sum of Rs. 7.00 Lakhs has been accepted by the ld. CIT (A) treating it as agriculture income. The balance amount of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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