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2022 (2) TMI 571

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.... on record as legal heir and in this respect invited our attention to the duly sworn in affidavit, filed by the legal heir as well as the copy of revised Form-36, along with the grounds of appeal. Learned D. R. had no objection for taking on record the legal heir. Therefore, legal heir was taken on record and Learned counsel for the assessee was asked to proceed with his arguments. 3. Learned counsel for the assessee submitted that the assessee had claimed certain agriculture income which the Assessing Officer had denied and had restricted the claim of agriculture income and therefore, the appeal was filed before the CIT(A) who again partly allowed relief to the assessee. Learned counsel for the assessee further submitted that the Assessin....

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....the basis of yield in the local area. He further submitted that in the earlier years the assessee did not disclose agriculture income and suddenly during the year he disclosed huge agriculture income which in fact is income from hidden sources and therefore, the Assessing Officer had rightly rejected the claim and learned CIT(A) has wrongly allowed substantial relief to the assessee and therefore, the appeal filed by the assessee may be dismissed. Similarly, regarding other sustenance of addition to the extent of Rs. 50,000/-, Learned D. R. submitted that the assessee had deposited huge amount of cash in his bank accounts against which the Assessing Officer confirmed addition of Rs. 2,04,000/- only and learned CIT(A) has restricted the addi....

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....to justify agricultural income. Therefore, I do not find any justification in the appeal of the assessee on this issue. Accordingly, the addition sustained by learned CIT(A) is upheld and on this ground, the appeal of the assessee is dismissed. 6. Now coming to the addition of Rs. 50,000/-, I find that the Assessing Officer had made the addition of Rs. 2,04,000/- out of total cash deposit in the bank account to the extent of Rs. 38,06,500/-. The Assessing Officer had noted in his order that such deposits were made in the bank account during the demonetization period. Still out of the total deposits, the Assessing Officer made addition of Rs. 2,04,000/- only and the learned CIT(A) restricted the addition to Rs. 50,000/- only. I find that be....