2025 (9) TMI 356

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....11-12 are reproduced as under :- "1. That on facts, and in law, the learned CIT(A) has grievously erred in confirming the reopening of assessment u/s.147 of the Act. 2. That the learned CIT(A) has grievously erred in law, and on facts, in confirming the addition of Rs. 27,67,834/- made as income from undisclosed sources, instead of accepting the same as agricultural income earned by the appellant and family members, completely ignoring the evidence on record furnished by the appellant. 3. That on facts, evidence on record, and as per law, the entire addition ought to have been deleted and genuine agricultural income which is also duly verified u/s.133(6) of the Act ought to have been accepted as such." 3. Asses....

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....esponse to the notice under Section 148 of the Act dated 04.11.2017 the assessee filed return of income thereby declaring taxable income at Nil and share in agriculture income at Rs. 1,49,000/-. Notice under Section 143(2) of the Act was issued and served to the assessee on 15.11.2017. The reasons recorded for reopening the assessment under Section 147 of the Act was supplied to the assessee on 15.11.2017 and the assessee filed objection on 06.02.2017 which was rejected vide order dated 08.12.2017. The Assessing Officer further observed that the assessee is doing house hold activity and having share income from agricultural income for which the assessee submitted books of account, cash book, bank book, coy of ITR, computation of total incom....

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.... accounts and bank details. Entries of large sums are also reflected in the bank account which was related to sanction/disbursement of housing loan from Union Bank of India and for that the assessee has submitted the details such as bank statement and certificates of the Bank alongwith affidavit from Mr. Hasmukhbhai Dalwadi in respect of the transactions. The Ld. AR further submitted that there was complete set of evidence produced before the Assessing Officer. In fact, there is confirmation which is also produced before the Assessing Officer including receipts of the Agricultural produce which was sold by the assessee and her family members in the Agricultural Produce Market Committee, Mehsana. All these documents clearly set out that the ....