2024 (10) TMI 241

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....nds of appeal: "1. On the facts of the case and in law, the Hon CIT(A) has erred in confirming the addition of Rs. 16,29,620/- being the amount of agriculture income from sale of cotton. 2. On the facts of the case and in law, the Hon CIT(A) has erred in confirming the addition of Rs. 11,64,680/- u/s 56(2)(vii)(b) as differential value of stamp duty and purchase price of the agricultural lands since agriculture lands are not a capital assets covered u/s 2(14). 3. Your appellant craves leave to add, alter or delete any or all of the above grounds of appeal either before or during the course of appeal proceedings." 2. None appeared on behalf of assessee despite service of notice of hearing on more than three occa....

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....n the computation of income, the assessee claimed net agriculture income of Rs. 18,25,745/-, however, in A.Y. 2014-15, the assessee has not shown any agriculture income. The assessee has shown bills of sale of cotton of Rs. 16,76,600/- without giving any expenditure. To verify the correctness of the claim and agriculture activities, the Assessing Officer issued summon to the assessee under Section 131 of the Act for recording his statement. Statement of assessee was recorded on 07/12/2017. The question and answer recorded by Assessing Officer is extracted at pave No. 2 to 4 of assessment order. The Assessing Officer also obtained information from the Department of Agriculture Economics, Junagarh Gujarat, wherein average gross receipt of cot....

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....of order of ld. CIT(A). In the submission, the assessee stated that he has declared total income at Rs. 96,980/- and agriculture income of Rs. 18,25,745/-. The assessee earned agriculture income of Rs. 16,76,000/- from cotton crop out of which the Assessing Officer allowed only Rs. 46,980/- and remaining was disallowed. The assessee has also shown agriculture income on sale of vegetable which was also disallowed. The assessee furnished copy of agriculture holding, sale bill and submitted that the assessee owned 36.42 acres of land which is cultivated by him only. The vegetables were sold in the local market and in addition to number of villagers directly purchased vegetables from spot. To support his submission, the assessee also relied on ....