TaxTMI 
TaxTMI 
2024 (12) TMI 986
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.... his proprietorship concern M/s. Sugi Petroleum: On facts and in the circumstances of the case and in law, Ld. CIT(A) by confirming the order passed by the Ld. AO has grossly erred in making addition of Rs. 25,26,619/- to the income of the appellant on account of capital introduction in his proprietorship concern M/s. Sugi Petroleum as the said introduction in the capital account were out of genuine source. The appellant craves leave to add, amend, alter, edit, delete, modify or change all or any grounds of appeal at the time of or before the hearing of the appeal. 2) Ad-hoc disallowances of Rs. 37,856/- being 10% of the total expenses of Rs. 3,78,562/-: On facts and in the circumstances of the case and in law, Ld. CIT(A) by confirming th....
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.... account of the assessee. Considering the facts, the source of cash deposit was explained as contemplated by the assessee and the same was accepted. During the course of assessment proceedings, the assessee submitted copy of land record and it was found that the assessee has not substantiated the cogent evidences which can prove the source of cash deposits. On perusal of the ITR for the assessment year 2016-17 and 2017-18, assessee has not claimed any agricultural income. Therefore, the Assessing Officer observed that the assessee has just colouring the transaction with his malafide intention and manipulated the source of cash deposits. The Assessing Officer further observed that the agricultural income of Rs. 25,56,619/- was earned during ....
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....well as the crop details related to the said agricultural land. The Ld. AR submitted that the Assessing Officer totally ignored the fact that the unutilised capital was reinvested in business by the assessee during the year under consideration i.e. assessment year 2017-18 and the same is accepted by the Assessing Officer. But while passing the order, the Assessing Officer has not taken cognisance of the same and passed the order by making addition of Rs. 25,26,619/-. The assessee is having more than 20 acres of land with his family and is having agricultural income approximately of Rs. 18,00,000/- to Rs. 20,00,000/- and during the year earned Rs. 17,51,005/- from the sales of various agricultural produce such as wheat, corn, paddy to the di....