TaxTMI 
TaxTMI 
2025 (1) TMI 1857
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....s. 132(2) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') was carried out on 14.10.2020 in the case of Manoj Kumar Singh & his Associates. During the course of search premises/locker of the assessee was also covered. From locker/premises of the assessee, cash Rs. 5,89,170/- and jewellery was found. The Assessing Officer (AO) made addition of Rs. 10,67,035/- u/s. 69A of the Act in respect of unexplained source for acquiring jewellery amounting to Rs. 10,67,035/- and unexplained cash Rs. 5,89,170/-. The assessee carried the additions in appeal before the CIT(A) and got partial relief. The addition made on account of jewellery was deleted by the CIT(A). However, addition with respect of cash found was upheld. The AR ....
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.... assessee had also placed on record affidavit of one of the neighbours of the assessee confirming the fact that parents of the assessee stay with him for certain months and keeps visiting native village for agricultural activities. Thus, the fact that father of the assessee earns agricultural income and cash amounting to Rs. 3.5 to Rs. 4 lakhs stand explained with supporting evidences. The part of cash found and seized belongs to the savings of the assessee's mother and wife. The AO and the CIT(A) have failed to controvert the submissions of the assessee. No document was brought on record by the Revenue to prove that the assessee has earned cash seized from undisclosed sources. The assessee has discharged its onus in proving sourc....
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.... and mother of the assessee. The assessee in order to substantiate agricultural income of father of the assessee has furnished copy of revenue records giving description of land owned, agricultural activities carried out, etc. at pages 87 to 92 of the paper book. A perusal of revenue records at page 87 and 88 of paper book reveal that father of the assessee is having land measuring 1.47 hectares approximately jointly owned with one Rajender Prasad Agarwal. Further, perusal of revenue records reveal that on the agricultural land Bajra and Wheat crops were cultivated. Thus, it can be safely presumed that father of the assessee was carring out agricultural activities. However, the assessee has not placed on record any documentary evidence to s....