TaxTMI 
TaxTMI 
2025 (3) TMI 2311
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....for the 2012-13. 2. Assessee has raised following grounds in its appeal: - "1. On the facts and circumstances of the case and in law, the learned CIT(A) has erred in maintaining addition of Rs. 6,06,643/- made by the AO on account of agricultural income. 2. Any other ground of appeal that may be raised at the time of hearing of the appeal." 3. Brief facts of the case are, search under section 132 of the Income Tax Act, 1961 (in short "Act") was carried out at the office premises of the company as well as the residential premises of the Directors and Family Members in the Group cases of M/s. Shree Agrawal Coal Pvt., Limited on 16.03.2011. Pursuant to search and seizure action under section 132 of the Act, the assessme....
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....cultural land and the details of the agricultural income including the ledger account. It is seen from the ledger account submitted by the assessee that all the receipts are stated in cash as under: Date Mode Amount 28.10.2010 By Cash 1,97,218/- 05.02.2011 By Cash 1,65,450/- 31.03.2011 By Cash 1,75,000/- The issue was examined by the AO in the remand report submitted by the AO on 05.02.2014. The AO has stated that the assessee has not shown any expenses for seeds fertilizer, water, electricity, diesel, transportation etc. The AO has further reported that in some of the sale vouchers, phone numbers of the buyers are mentioned and almost all the phones are not in existence and some persons out of t....
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....income which is exempt from income tax does not appear to be genuine. All the sales are in cash and on self made vouchers/ bills and wherever phone numbers have been mentioned, they are not in existence. The party which attended before the AO during the remand proceedings has denied having purchased the agricultural produce from the assessee. The assessee has not been able to submit bills of expenses claimed to have been incurred in the agricultural operations. In the facts and circumstances stated above, the claim of agricultural income of Rs. 2,21,886/- made by the assessee is held as a ploy to launder his unaccounted money into the books as agricultural income which happens to be exempt from Income Tax. The addition of Rs. 2,21,....
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....quantum rise in the agricultural income the same cannot be doubted. He accordingly, prayed that the addition be deleted. 6. Per contra, Ld. CIT(DR) (in short "Ld.DR") strongly pressed that in the absence of corroborative evidence regarding the performance of the agricultural activity the addition has been rightly made and no interference is called in the factual finding of two concurrent authorities. 7. We have heard both the sides. The crucial point i.e. emanating here is that the appellant has miserably failed to prove its claim of agricultural income not only this year but also for A.Y. 2011-12. Finding in the earlier year i.e., A.Y. 2011-12 was remained unchallenged as the Assessee has not carried the matter before the Tribunal, f....