2026 (1) TMI 752

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....6.12.2019. 2. Grounds of appeal raised by the assessee are as under: "1. The grounds of appeal mentioned hereunder are without prejudice to one another. 2. The Id. Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi (hereinafter referred to as the "CIT(A)"] erred in confirming addition made by AO of Rs. 4,81,036/- by estimating production of wheat and coriander at 3640 Kgs and 960 Kgs as against the actual production and thereby treating excess income from agriculture activities as income from undisclosed source on the alleged that the assessee failed to produce sales bills. The addition made and confirmed is bad in law as also on facts therefore the same may kindly be deleted. 3.Your H....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....sessee has claimed agriculture expenses of Rs. 2,46,760/- i.e. 30% of gross agriculture receipts. The assessee's total agriculture land holding is only 1-24-45 hectare i.e. 7.69 Vigha. During the year under consideration, the assessee has claimed to cultivation of winter crops of wheat in 3.31 vigha and coriander in 2.74 vigha. As per data collected from Agriculture University, Junagadh, the highest production of wheat per vigha comes to 1100 Kg i.e. 55 Man and coriander production is 350 Kg i.e. 17.50, Man per Vigha in the region of Junagadh District. Considering the area utilized for cultivation of wheat and coriander, the maximum production of wheat comes to 3640 Kg and coriander at 960 Kg. As per data collected from Agriculture Univ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.....74 vigha. The AO logically explained acreage produce per vigha with the support of agriculture university data in the region of Junagadh and arrived net income of Rs. 86,204/- in the light of agriculture university data. Thus, the excess income of Rs. 4,81,036 from agriculture was the income from the undisclosed source and therefore, learned CIT(A) confirmed the addition made by the assessing officer. 5. Aggrieved by the order of the Ld. CIT(A), the assessee is in appeal before this Tribunal. 6. Learned Counsel for the assessee, submitted that the only addition made by the assessing officer is to the tune of Rs. 4,81,036/-. It is very small addition, therefore an adhoc and estimated disallowance of Rs. 50,000/- may be made in the han....