9911796707
TMI Blog2002 (1) TMI 255X X X X Extracts X X X X X X X X Extracts X X X X ..... o the asst. yr. 1980-81. The common grounds of appeal are as under: "1. The CIT(A) has grossly erred in upholding the reopening proceedings under s. 147(b) of the IT Act though the proceedings for reopening were initiated under s. 147(a) of the IT Act by the AO to which the assessee has objected to. 2. The CIT(A) has grossly erred in not commenting upon the report of handwriting expert though ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g 1/2 share therein and invested Rs. 35,000 each. The assessment was completed under s. 143(1) of the IT Act, 1961. Subsequently, when the case was scrutinised while making the assessment for the asst. yr. 1981-82, in which the assessees had declared short-term capital gains on the sale of the same plot, the AO enquired about the source of the investment in the acquisition of the plot and then fou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... favour with the AO, who made the additions of Rs. 35,000 in each case treating the same as income from undisclosed sources. 3. It was contended before the learned CIT(A) that each assessee disclosed full particulars of their agricultural income, as per following details: Asst. yr. Amount 1974-75 4,500 1975-76 4,000 1976-77 5,000 1977-78 4,500 1978-79 4,500 1979-80 4,500 1980-81 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h the assessees had shown agricultural income and the same was accepted and assessed by the Department. The assessees had shown the investment in the same plot in the wealth-tax returns for the asst. yr. 1980-81 and the returns were filed on 8th July, 1980 while in the income-tax matters, the returns were filed on 8th Oct., 1980. From these facts, it cannot be denied that the assessees were not (s ..... X X X X Extracts X X X X X X X X Extracts X X X X
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