1984 (3) TMI 208

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....year 1975-76 are conveniently disposed for the year common order. The appeal of the Department is against the deletion of a sum of Rs. 10,000 against the addition made by the ITO of Rs. 19,800 to the income of the assessee. In the cross-objection the assessee agitates its grievance against addition of Rs. 9,800 sustained by the AAC and also the levy of interest under ss. 139(B) and 217. The questi....

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....tement except filing certain letters from one or two agriculturists in support of the claim that it is a practice to make advance agaisnt supply of fertilizers. In the circumstances, the ITO rejecting the explanation added the aggregate of the credits in the assessee's income. The ITO further noticed that the assessee had advanced a sum of Rs. 15,000 on 12th Feb., 1975 to one Velusamy on mortgage.....

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....e of the assessee could be estimated at Rs. 10,000 per year. He, therefore, contended that credit should be given to the savings out of agricultural income which cover the amounts of credits. The AAC considering that the original explanation given by the assessee was not a considered one and was not given realising the full consequence thereof held that the explanation as to be credit having come ....

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....dits represented advance agaisnt supply of fertilizer. It is also undisputed that the assessee was having agricultural income for the past number of years and even according to the ITO such income may be estimated at Rs. 10,000 per year. Therefore, I do not find anything unreasonable in the AAC holding that the credits at least to the extent of Rs. 10,000 could be reasonably said to have come out ....