2025 (11) TMI 1480

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.... For the Revenue : Shri B.P. Srivastava, Sr. DR ORDER PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER: This is an appeal filed by the assessee against the order of the Additional/Joint Commissioner of Income Tax (A)-1, Nashik (in short "the Addl. CIT(A)") dated 30.12.2024 for the Assessment Year (A.Y.) 2017-18 in the proceedings under Section 143(3) of the Income Tax Act, 1961 (hereinafter ....

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....er found that the agricultural expense was only 32.83% of the gross agricultural receipt, which was low considering the fact that the ITAT in the case of Shri Dhirubhai L. Narola & Others had upheld the agricultural expense of 40% of the gross agricultural receipt. Accordingly, the Assessing Officer held that the agricultural expense incurred by the assessee should be 40% of the gross agricultural....

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....actually incurred by assessee. The addition made by the Honourable CIT(A) deserves to be deleted. The same be deleted now. 2. The Honourable CIT(A) has erred in not properly appreciating the facts, various submissions, explanations and information submitted by the appellant from time to time which ought to have been considered before passing the impugned order ex-parte due to non-attendan....

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....f agricultural expense in a third-party case cannot be automatically applied to the present case. 7. Per contra, Shri B.P. Srivastava, Ld. Sr. DR relied upon the orders of the lower authorities. 8. We have carefully considered the rival submissions. In the course of assessment, the assessee had brought on record evidences for agricultural expense of Rs. 37,28,364/- incurred by her, which was....