TaxTMI 
TaxTMI 
2025 (4) TMI 2188
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....the assessment year 2021-22. 2. The assessee has raised the following grounds of appeal: 1. The orders of the authorities below in so far as they are against the appellant are opposed to law, equity, weight of evidence, probabilities, facts and circumstances of the case. 2. The learned CIT[A] is not justified in sustaining the addition of Rs. 7,48,000/- made under the head Income from "Other Sources" in respect of the agricultural expenses incurred and claimed by the appellant on the mistaken notion that there was a double claim of expenditure under the facts and in the circumstances of the appellant's case. 2.1. The learned CIT[A] ought to have appreciated that the agricultural expenses debited to the curr....
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....assessee has not submitted any documentary evidence, in spite of giving several opportunities. Therefore, the AO completed the assessment u/s. 143(3) r.w.s. 143(3A) & 143 (3B) of the Act on 09.03.2021 by disallowing the expenditure of Rs. 7,48,000/- and treated the same as income from "other sources" and added to the total income of the assessee. 4. Aggrieved by the order of the Assessing Officer, the assessee preferred an appeal before the ld. CIT(A)/NFAC. 5. During the course of the Appellate proceedings, the assessee did not file any details/documentary evidences in support of the grounds of appeal despite giving sufficient time and multiple opportunities of being heard. Under the circumstances, in the absence of any details or doc....
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....ce and agriculture income earned by the assessee is accepted by the AO and there is no dispute regarding this. Further, the AO observed that all the expenditure relating to the payments to gardener and watchman, labour payments, local manure, mud and transportation expenses and cultivation expenses were booked in the firm's account only on monthly basis. The ld. AO is of the view that since the firm is not having any other land holding, the expenditure shown in the individual capacity appeared to be a double claim as the same was already claimed in the firm's capacity. Accordingly, the ld. AO disallowed the expenditure of Rs. 7,48,000/- in the hand of the individual & added under head "Income from Other Sources" as the AO was of the view th....
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.... in the Current capital account as drawings of the partner and not as expenses of the partnership firm as alleged by the AO. In the present case, the agricultural income of Rs. 46,35,180/- has been claimed by the assessee in his individual capacity as exempt under section 10 of the Act as the assessee is the owner of the agriculture land and we also find that the source of meeting these agriculture expenses were drawing from the capital of his firm namely M/s. D.M. Manjunath & Sons. Therefore, we are of the considered opinion that the assessee has not claimed the amount of agricultural expenditure twice as alleged by the AO. We agree with the contention of the AR that the AO on a mistaken note had treated the drawings of the assessee from t....