2026 (5) TMI 1131

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....nani, Addl. CIT, Sr. DR ORDER PER GEORGE MATHAN, JM: This is an appeal filed by the assessee against the order of the CIT(A), Central NER, Guwahati [hereinafter referred to as the 'CIT(A)'] in appeal no. CIT(A), Central NER, Guwahati/10075/2018-19 dated 19.09.2025. 2. Shri S. P. Bhati, FCA, represented on behalf of the assessee and Shri Santhosh Kr. Karnani, Sr. DR represented on behal....

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.... the verification unit has found that the assessee was doing agricultural operation and that the assessee was in the activity of floriculture, the addition as made by the Assessing Officer is liable to be deleted. It was the submission that the addition cannot be made on suspicion and surmises. 4. In reply, the ld. Sr. DR submitted that opportunity had been given to the assessee and even show-c....

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....essing Officer however mentioned that the assessee has not responded to the notice issued u/s 142(1) dated 09.09.2022. However, it is noticed that the response of the assessee to the show-cause notice itself is elaborate and the explanation given by the assessee has not been disproved. The Assessing Officer made the disallowance only because he felt that the cash deposits were from the agricultura....