9911796707
TMI Blog2024 (3) TMI 1353X X X X Extracts X X X X X X X X Extracts X X X X ..... financial years. Assuming for a moment, the assessee derives agricultural income at Rs. 6,00,000/-, it cannot be said that the assessee has saved entire agricultural income without spending for his day-to-day expenses. Therefore, considering the amount of agricultural income declared by the assessee for last two financial years, we are of the considered view that a reasonable amount can be attributable towards savings, which can be kept in cash balance. Therefore, out of total agricultural income declared by the assessee, we consider a sum of Rs. 2,00,000/- towards expenses of the assessee for two years and balance sum of Rs. 4,00,000/- is available with the assessee in the form of cash in hand which can be considered as source for cash de ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ave earned income from money lending business and agricultural activities. The assessee has filed his return of income for the assessment year 2017-18 on 06.03.2018, admitting a total income of Rs. 3,75,350/- and agricultural income of Rs. 50,000/-. The case was selected for scrutiny under CASS to verify large cash deposits during demonetization period. During the course of assessment proceedings, the Assessing Officer noticed that total credits in Indian Bank account of the appellant was at Rs. 36,34,071/- and out of which sum of Rs. 13,81,000/- is cash deposited in specified bank notes during demonetization period. The Assessing Officer, called upon the assessee to furnish necessary evidences and also explain source for cash deposits. In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dhar, Advocate (Erode), submitted that the ld. CIT(A) erred in not considering opening cash in hand available with the assessee, which is generated out of income earned for last two years, out of agricultural income declared in the return of income filed for the relevant assessment years. The Ld. Counsel for the assessee, further submitted that the balance amount of cash deposits is out of collection from sundry debtors from assessee s money lending business. Therefore, he submitted that additions made by the Assessing Officer should be deleted. 6. The ld. DR, on the other hand supporting the order of the ld. CIT(A) submitted that, the assessee could not file any evidence to prove income from agricultural operations. The assessee had also n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ces, the possibility of keeping opening cash in hand out of agricultural income declared for last two financial years cannot be ruled out. The assessee has filed ITRs for last two financial years and as per ITRs filed by the assessee, the assessee has declared about Rs. 6,00,000/- agricultural income for two assessment years. The assessee has not declared any other income in the return of income filed for last two financial years. Assuming for a moment, the assessee derives agricultural income at Rs. 6,00,000/-, it cannot be said that the assessee has saved entire agricultural income without spending for his day-to-day expenses. Therefore, considering the amount of agricultural income declared by the assessee for last two financial years, w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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