ITAT allowed the assessee's appeal, deleting the addition made by the AO on account of capital introduced in the business. ITAT held that duly executed agreements to sell agricultural land, evidencing full receipt of sale consideration, along with details of sellers, buyers, PAN, and photo identity, constitute a plausible and satisfactory explanation of the source of funds. It was held unjust for the AO to discredit these agreements merely due to non-execution of registered sale deeds, particularly in the context of joint landholdings and co-sharers where specific survey-wise conveyance may not be feasible. In the absence of any independent inquiry or rebuttal by the Revenue, the source of capital could not be doubted, and the addition was unsustainable.
ITAT allowed the assessee's appeal, deleting the addition made by the AO on account of capital introduced in the business. ITAT held that duly executed agreements to sell agricultural land, evidencing full receipt of sale consideration, along with details of sellers, buyers, PAN, and photo identity, constitute a plausible and satisfactory explanation of the source of funds. It was held unjust for the AO to discredit these agreements merely due to non-execution of registered sale deeds, particularly in the context of joint landholdings and co-sharers where specific survey-wise conveyance may not be feasible. In the absence of any independent inquiry or rebuttal by the Revenue, the source of capital could not be doubted, and the addition was unsustainable.
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