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1978 (10) TMI 54

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..... ted that he is an agriculturist and the investment in question was made out of the past agricultural income savings. It is stated by the assessee that he has been carrying on agricultural operation right form the time when he was settled in 1948 at Jullunder after partition. The ITO did not believe the explanation of the assessee. The assessee claims himself to be the expert in vegetable farming. His contention is that he prepares his own seeds and Paniris. It is urged that part of the vegetable grown by the assessee are being marketed and part of the vegetables are being sold on spot. He contends that may customers buy the standing crops of the assessee and then they carry the vegetable from the assessee's farm to the market themselves. Th .....

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..... niris had not been considered by the ITO. He also contended that the savings of the year 1970-71 could not constitute to be a good guideline for estimating the assessee's savings of the past years. He contended that the asst. yr. 1970-71 was bad as the whole crop was affected by pests etc. Considering the plea of the assessee that the sale proceeds of the standing crop and Paniris were not considered by the ITO, the AAC reached a conclusion that he assessee was entitled to a further benefit of Rs. 12,000. He, therefore, sustained the addition of Rs. 20,000. 4. This is how the assessee has come up in appeal to the Tribunal. Before us, Shri Gupta, the ld. Counsel for the assessee, urges that he authorities bellow have not considered the ca .....

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..... pears to the a substance in the arguments of Shri Gupta. It is a matter of common knowledge that vegetable farming is more lucrative than other crops. Admittedly the land of the assessee is adjacent to the city. So the assessee has an advantage of selling the vegetable products on spot itself. Shri Gupta argues that the assessee took certain land on lease on payment of Rs.10,000 per year at Kapurthala in the year 1952 for a period of three years. He argues that the assessee had the agricultural savings of Rs. 10,000 as back in the year 1952 and his progressiveness can be judged from this factor also. The AAC does not appear to be justified in estimating the savings of the assessee at Rs. 12,000. When the assessee carried on agricultural ope .....

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