2022 (6) TMI 736

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....the issue are stated in brief. The assessee is an individual and is non-resident. During the year under consideration, the assessee has deposited cash of Rs. 15 lakhs during the demonetization period. The assessee explained the sources to be the sale proceeds of coffee seeds. It was stated that coffee seeds were sold to M/s. Raj Coffee Curing Works. The assessee also furnished copies of two purchase invoices issued by above said concern for a sum of Rs. 8,10,000/- and Rs. 6,89,775/-. The AO noticed that the assessee had declared meager agricultural income of Rs. 29,500/- and Rs. 69,275/- respectively in Assessment Years 2016-17 and 2017-18. Further, it was noticed the assessee had sold his agricultural land during the financial year 2013-14....

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....fter completion of the assessment proceedings. The Ld. AR submitted that the explanation given by the assessee has been confirmed by third party M/s. Raj Coffee Curing Works. The Ld. A.R reiterated that considering the fact that the assessee was nonresident during the year under consideration, there is no scope to presume that the assessee had generated unaccounted income. Accordingly, by placing reliance on the decision rendered by Hon'ble Supreme Court in the case of CIT Vs. Smt. P K Noor Jahan 237 ITR 570, the Ld. AR submitted that there is no reason to disbelieve the explanation furnished by the assessee. Accordingly, he prayed that the addition of Rs. 15 lakhs should be deleted. 4. The Ld. DR, on the contrary, submitted that the a....