2026 (4) TMI 1174

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....gh, Sr.DR ORDER PER BENCH: The present appeal is filed by assessee against the order dated 24.09.2025 passed by Ld. Commissioner of Income Tax (A)/ADDL/JCIT(A)-1, Nashik ["Ld. CIT(A)"] in Appeal No. CIT(A), Dehradun/10344/2019-20 u/s 250 of the Income Tax Act, 1961 ["the Act"] arising out of assessment order dated 01.11.2019 passed u/s 143(3) of the Act pertaining to Assessment Year 2017-....

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....re us, in respect of Ground of appeal No.2, Ld.AR regarding disallowance u/s 40(ia) of the Act, ld. AR for the assessee drew our attention to the ledger account of interest paid to Pradeep Sharda HUF where TDS was deducted of INR 50,520/- and also filed copy of TDS return. Ld. AR further submits the copy of Form 26AS statement of the recipient Pradeep Sharda HUF wherein TDS made by assessee is dul....

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....owed. 7. Ground of appeal No.3 raised by the assessee is with respect to addition of INR 6,25,000/- treated as agricultural income as unexplained money. 8. Before us, Ld.AR for the assessee submits that assessee's father, Shri Satish Chandra Sharda owned large area of land where the Apples and other fruits are grown. After his death, the assessee received his share of 7,500 apple trees and f....

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....ot doubted the merely ownership of Apple trees by the assessee nor any enquiry was made from the parties to whom apples were sold and merely by alleging that in preceding year, agricultural income was shown less, the income declared in the year under appeal was doubted. Ld. AR thus prayed for the deletion of addition made. 9. On the other hand, Ld. Sr. DR for the Revenue vehemently supported th....