2025 (6) TMI 790

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....elevant to the Assessment Year 2017-18. 2. The grounds raised are as under:- "1.1 The order passed by U/s.250 passed on 19.06.2024 by NFAC, [CIT(A)], Delhi (for short CIT(A)" upholding the addition of Rs. 17,38,500/- towards cash deposits in various bank accounts as unexplained money u/s 69A rws 115BBE is wholly illegal, unlawful and against the principles of natural justice. 2.1 The Id. CIT(A) has grievously erred in law and or on facts in upholding that the addition of Rs. 17,38,500/- towards cash deposits in various bank accounts as unexplained money u/s 69A rws 115BBE. 2.2 That the in the facts and circumstances of the ld. CIT(A), ought not to have upheld the addition of Rs. 17,38,500/- towards cash deposit....

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....ownership of agricultural land which is noted to be 1.64 vigha in his name and 3.50 vigha jointly owned with his family members, thus in all 5.15 vigha of land. The Ld.CIT(A) also notes the fact of the assessee having taken crop loan from the Oriental Bank of Commerce for conducting his agricultural activities amounting to Rs. 3,66,000/- and Rs. 12,10,000/-. Copy of the loan account was also submitted as evidence to the CIT(A), as also the fact of the loan being repaid regularly in all the previous years from the income generated through sale of agricultural produce. Copies of the loan sanction letter as well as loan repayment details from the bank were submitted. 5. Having noted so, we find that the ld. CIT(A) did not find the assessee'....

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.... appellant could not explain why similar cash deposits were not made in the earlier years, if the activity of the appellant is same in those years also. 6. The appellant could not explain the reason for the receipt by way of cash even though there is a branch of nationalized bank in the place of his residence." 6. It is evident from the above that the Ld.CIT(A) has given cognizance to the evidences submitted by the assessee. However at para 5.5 I note that he has considered the same and after consideration has found that agricultural income to the tune of Rs. 2 lakh per vigha may be allowed to the assessee to meet the end of justice as under:- "5.5 Accordingly, the addition made by the AO is appears to be correct and su....