2025 (5) TMI 362

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....rt) for the Assessment Year (AY) 2020-21. 2. The core ground raised by the assessee is as under: "[1] The Ld. CIT(A), NFAC, Delhi is grievously erred in determining the disallowance of the balance amount of Rs. 14,33,983/- at the rate of 15% of agriculture income out of the total disallowance of Rs. 28,67,967/- being the estimate of 30% expenses of net agriculture income is quite illegal and unreasonable and wrong concept. ...." 3. The brief facts of the case are that the assessee is engaged in agricultural activities and has filed his return of income for the year under consideration on 30.03.2021 determining income of Rs. 9,80,080/- and declaring agricultural income of Rs. 95,59,891/-. The Assessing Officer completed the assessment ....

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....s of section 115BBE of the Act." 4. Aggrieved by the order of the Assessing Officer, the assessee filed appeal before the Ld. CIT(A) who restricted the disallowance to 15% of the agricultural income of Rs. 95,59,892/-, resulting in confirming the addition of Rs. 14,33,984/- u/s 68 of the Act. 5. Aggrieved by the order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal. 6. We have heard the rival contentions and perused the material available on record. We find that the Assessing Officer made an addition at the rate of 30% of net agricultural income of Rs. 95,59,891/- i.e. Rs. 28,67,927/-, being unexplained cash credit u/s 68 of the Act, since the assessee has failed to substantiate his claim of low expenses incurred of ....