https://www.taxtmi.com/caselaws?id=783499 ITAT Agra partly allowed the assessee's appeal. On characterization of income, the Tribunal held that agricultural income was acceptable only to the extent attributable to agricultural land legally owned by the assessee; agricultural income claimed from land owned by the assessee's brother was unsupported by independent documentary evidence and was therefore liable to be taxed as "income from other sources." On reopening under s.147 and addition under s.68, ITAT held that the AO had already examined unsecured loans in the original scrutiny, accepted the explanations, and made no addition, and the alleged election affidavit disclosed no new material. Reassessment was thus a mere change of opinion and invalid, and no addition under s.68 was sustainable. en-us Fri, 12 Dec 2025 00:00:00 +0530 Wed, 17 Dec 2025 08:28:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783499 ITAT Agra partly allowed the assessee's appeal. On characterization of income, the Tribunal held that agricultural income was acceptable only to the extent attributable to agricultural land legally owned by the assessee; agricultural income claimed from land owned by the assessee's brother was unsupported by independent documentary evidence and was therefore liable to be taxed as "income from other sources." On reopening under s.147 and addition under s.68, ITAT held that the AO had already examined unsecured loans in the original scrutiny, accepted the explanations, and made no addition, and the alleged election affidavit disclosed no new material. Reassessment was thus a mere change of opinion and invalid, and no addition under s.68 was sustainable. Case-Laws Income Tax Fri, 12 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783499