2019 (2) TMI 1432

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.....R. ORDER The aforesaid appeals have been filed by the assessee against separate impugned orders dated 18.9.2017, passed by Ld. CIT(Appeals) Aligarh for the quantum of assessment u/s 144/147 for the assessment year 2008-09; and order dated 18.9.2017, in relation to the penalty proceedings u/s 271(1)(c) for the same assessment year. 2. The facts in brief are that, on the basis of AIR infor....

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....purchase deed was also filed before him. It was submitted that she has paid the purchase consideration over the period of five years to her father out of her savings, gifts from relatives and agricultural income. This fact was also duly confirmed by her father through his affidavit and also by the assessee in her affidavit. It was submitted that the copy of the affidavit was also filed before the ....

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....ioned that the property in concern was agreed to be purchased from her father and agreement was entered 5 years earlier and the amount of Rs. 10 lacs have been paid over the period of five years. Looking to the fact that assessee was having agricultural income, Ld. CIT(A) accepted that sum of Rs. 5 lacs can be treated to be explained out of agricultural income, however the balance amount was confi....

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....ee does not have any source of income other than agricultural income and department itself has accepted that in the return of income assessee has shown agriculture income of Rs. 2,50,000/-. Once assessee has no source of income other than agricultural income then to hold that she must have made investment out of her unexplained sources would be very difficult to believe. Further, when factum of ag....