2015 (4) TMI 1127

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....disbelieving the version of the assessee regarding the advances paid for the purchase of agricultural lands during the relevant years? 2. Whether in the facts and circumstances of the case, the Income Tax Appellate Tribunal is justified in treating the advances given by the assessee as cash on hand and treating the same as addressable under the Wealth Tax Act? 3. Whether in the facts and circumstances of the case, the Income Tax Appellate Tribunal is justified in disbelieving the proof produced by the assessee to substantiate the advances paid for purchase of agricultural land without there being any valid reasons being attributed by the department to the contra? 4. Whether in the facts and circumstances of the case, the Income Tax....

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....f the assessees that they have ever cultivated the agricultural land in any of the years. Since the opening cash balance as on 31.3.2001 was shown by the assessees in their cash flow statement filed before the CIT(A), the onus is upon them to prove the accumulation of the opening balance as on 31.3.2001. Neither before the lower authorities, nor before us the assessees could place a satisfactory explanation about the accumulation of the opening balance." On the issue with regard to brokerage income of HUF, the learned Tribunal has found as follows: "We find that in this regard also nothing has been placed before us to prove that the HUF was engaged in the business of brokerage. Therefore, whatever income from brokerage was declared in....