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of The ITAT Bangalore, in a case involving unexplained money u/s. 69A, addressed deposits in a bank account during the demonetisation period. The DR argued that the assessee failed to provide external evidence supporting the agricultural income declared. The tribunal noted the average agricultural income reported by the assessee for the previous three years. It observed that the AO had accepted the agricultural income while computing the total income, which is crucial for raising a demand u/s 156. Consequently, the AO could not treat it as unexplained investment u/s. 69A. The tribunal accepted the assessee's plea, considering the income as agricultural income and applying the normal tax rate. As the assessee had shown agricultural income of Rs. 15,84,000 in the return, with a portion accepted by the ld. CIT (A), the remaining amount was also deemed agricultural income. Therefore, the assessee's appeal was allowed.
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