2025 (7) TMI 864

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....grounds of appeal: "1. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming the action of assessing officer in making the addition of Rs. 3,45,000/- on account of unexplained money u/s. 69A. 2. Even otherwise on the facts and circumstances of the case as well as law on the subject, the assessing officer has erred in taxing the income of Rs. 3,45,000/- u/s. 115BBE @ 77.25% in a retroactive manner by applying the duty substituted S. 115BBE inserted retrospectively instead of taxing it at 35.54% as per the old provisions of S. 115BBE. 3. It is therefore prayed that the above addition made by the assessing officer and confirmed by Ld.CIT(A) may please be ....

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....of Rs. 1,00,000/- was made from the HDFC Bank account on 04.07.2016 which further contributed to the cash on hand of Rs. 3,45,000/-, along with receipts from agricultural income. Upon reviewing the submissions, the Commissioner (Appeals) was of the view that the documents provided by the assessee, such as the agricultural income accounts and sales bills, were self-serving documents and lacked third-party confirmation, making them unverifiable. The property details filed by the assessee showed that the land was jointly owned by over nine individuals, with no clarity on the assessee's share or the agricultural income attributable to him. Furthermore, the assessee had not declared any agricultural income in any subsequent years, and no new evi....