Appeals partly allowed with profit estimation upheld at 5% and agricultural income treated as other income.

The appeals were partly allowed with the Tribunal upholding the estimation of profit from liquor business at 5% and treating a portion of agricultural income as income from other sources. The additional ground challenging assessment under section 153C was dismissed as not pressed.

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Issues:
1. Delay in filing appeals and condonation application.
2. Estimation of profit from liquor business.
3. Treatment of agricultural income.
4. Additional ground challenging assessment under section 153C.

Analysis:
1. The appeals were filed against orders dated 04.09.2019 by the Commissioner of Income tax for AY 2015-16 & 2016-17. The delay of one day in filing the appeals was condoned after the assessee provided reasons. The Tribunal recalled its earlier orders dismissing the appeals for want of prosecution.

2. In the first appeal, the assessee challenged the estimation of profit from liquor business at 5% of turnover. The AO estimated profit at 8% due to lack of maintained books of accounts. The CIT(A) restricted profit at 5%, which the assessee contested, seeking 3% based on a Tribunal decision. The Tribunal upheld the CIT(A)'s decision, considering the absence of maintained accounts and the assessee's admission of 5% profit.

3. Regarding treatment of agricultural income, the AO added Rs.52,500 as income from other sources due to lack of details provided by the assessee. The CIT(A) sustained the addition, but the assessee submitted a VRO certificate later. The Tribunal partially allowed the appeal, directing the AO to restrict the disallowance to 10% of the income shown, sustaining Rs.10,500 addition.

4. In the second appeal for AY 2016-17, similar issues were raised. The Tribunal upheld the CIT(A)'s decision to estimate liquor business profit at 5% and treat 10% of agricultural income as income from other sources. The additional ground challenging assessment under section 153C was not pressed.

In conclusion, both appeals were partly allowed with the Tribunal upholding the estimation of profit from liquor business at 5% and treating a portion of agricultural income as income from other sources. The additional ground challenging assessment under section 153C was dismissed as not pressed.

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