Agricultural income claim from sibling's land and s.147 reopening for s.68 loans rejected as unsupported, change of opinion

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....Agricultural income was partly disallowed because the taxpayer failed to substantiate cultivation and entitlement to agricultural income from land owned by a sibling; a bare assertion and sibling confirmation, without corroboration such as evidence that the sibling did not declare such income, was held insufficient, so agricultural income was accepted only proportionately to the taxpayer's own land and the balance was assessed as income from other sources. Reassessment under s.147 to tax unsecured loans under s.68 was invalid since the issue had been specifically examined in the original scrutiny and accepted, making reopening a mere change of opinion; the election affidavit disclosed no adverse new material and there was no fresh loan receipt during the year, so jurisdiction failed and the addition was deleted. - ITAT....