2025 (11) TMI 1386

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....hat the assessee had deposited more than Rs. 10 lacs in different saving bank accounts maintained by him during the F.Y. 2014-15 relevant to AY 2015-16. A query letter as well as a notice u/s. 133(6) of the Income Tax Act, 1961 was issued and served upon the assessee asking him to furnish the source of income and credit entries thereof in bank accounts maintained by him. But the assessee failed to furnish any satisfactory explanation. Further no return of income was filed by the assessee for the year under consideration. Accordingly, reassessment proceedings were initiated in the case of the assessee. During the course of reassessment proceedings, the appellant was asked to furnish details and source of cash deposit. In response, the assess....

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.... 5. At the time of hearing, Ld. AR has submitted that assessee is an individual, engaged in agricultural activities. During the relevant assessment year, the Assessee sold agricultural land situated at Village Rehadva, Tehsil and District Bijnor, Uttar Pradesh, belonging to himself and his father. The sale proceeds were received in cash, as is customary in rural agricultural transactions in the region, and were subsequently deposited into the Assessee's bank account. Copy of Agreement to Sale and Sale deed and copy of bank statement are placed on record. He further submitted that date of agreement to sell was 25th April 2014 and date of sale deed is 25.11.2014. All the cash was deposited between these dates Rs 7,00,000/- was deposited on 2....

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....ition, without properly appreciating the documentary proof or providing a reasoned rebuttal, thereby perpetuating the error. It was submitted that the agricultural land in question is rural agricultural land, as defined under Section 2(14) of the Act (excluding it from the definition of 'capital asset'), and the income from its sale is exempt under section 10(1) read with Section 2(1A) of the Act, being agricultural income. The cash deposits, therefore, represent explained sources and do not warrant treatment as unexplained under section 69A. Per contra, Ld. DR relied upon the orders of the authorities below. 6. Before me the ld. AR submitted a paper book containing pages 1-99 having the copy of reply, agreement of sell (in case of Jiten....