2022 (12) TMI 1379

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....ned Commissioner of Income-Tax (Appeals), Meerut for the assessment year 2010-11. 2. The dispute in the present appeal is confined to addition of Rs.20,63,695 under Section 68 of the Income-Tax Act,1961. 3. Of course, the assessee has raised some other grounds including additional grounds challenging the validity of assessment order passed under Section 147 read with section 144 of the Act. 4. ....

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....ssessee to explain the source of such investment. In response, the assessee submitted that he received loan of Rs.4,00,000 from his mother, Rs.3,00,000 from his brother and he received an amount of Rs.24,00,000 from sale of potato crops. 7. After considering the submissions of the assessee, the Assessing Officer partly accepting assessee's explanation accepted the source of investment to the exte....

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....balance amount. 9. I have considered rival submissions and perused the material available on record. 10. As could be seen from the facts on record to explain the source of investment in purchase of land amounting to Rs.45,78,550, the assessee has submitted that Rs.21,70,000 were out of earlier withdrawals from various bank accounts in name of self, father and mother. Whereas, the balance amount ....

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....24,00,000. He has rejected balance amount only because sale invoices were not produced by the assessee. 12. The fact that the assessee has sold agricultural produce, cannot be disputed because, even, the departmental authorities have accepted a part of assessee's receipts from sale of agricultural produce. Only a part of amount claimed to have been received from sale of potato has been rejected d....