2021 (7) TMI 249

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....9 days delay stated to be attributable to the reason(s) beyond his control as per condonation petition/affidavit. No rebuttal has come from the departmental side. The impugned delay is condoned therefore. 3. The assessee has pleaded the following substantive grounds in the instant appeal: "2. On the facts and in the circumstances of the case, the learned Commissioner of Income Tax (Appeals), erred in upholding the addition of Rs. 24,17,633/- made by the Assessing Officer. 3. The learned Commissioner of Income Tax (Appeals) ought to have appreciated that the assessee furnished evidence in support of the agricultural land holdings and income there from in support of the sources for availability of money towards expenditure incurred on as....

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....cept to obtain bank loan subject to rules and regulations of the bank." Hence, these agricultural income certificates were only for the purpose of bank loans and not valid for any civil proceedings or criminal proceedings. Therefore, these certificates do not carry merit in Direct Tax proceedings which are civil proceedings. From the assessment order and also from the details, it is apparent that the appellant did not have that amount of agricultural income to be in the possession of a substantial amount of money. The AO in his order has brought out the details. The explanations offered in appeal are clearly in the nature of an after-thought. The agricultural land holdings and the appellant return incomes do not provide for such large a....