TaxTMI 
TaxTMI 
2026 (10) TMI 422
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.... 1. The order of the learned appellate authority is opposed to law on the facts and circumstances of the case. 2. Both the assessing officer and the learned appellate authorities have failed to go through the details of land holdings of the assessee and copy of patta chitta and other records from the State Government regarding agricultural income. 3. The learned appellate authorities have concluded that no evidence was filed before them for the agricultural income but failed to note the same details which were furnished before the assessing authorities. 4. Both the assessing officer as well as the learned appellate authorities have failed to note that the assessee is earning agricultural income year after....
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....tion in full. 10. For these grounds and such other grounds that may be adduced at the time of hearing, it is prayed that the order of the assessing officer be reversed and relief granted to the assessee as sought. 2. The brief facts of the case are that the assessee is an individual and has filed return of income on 28.03.2023 declaring a total income of Rs. 3, 82, 020/-. The case was selected for scrutiny assessment under CASS. The nature of business as reflected in the ITR is retail sale of other products. The taxpayer has reported a turnover of Rs. 18,95,671/- but the total cash withdrawal is Rs. 55, 97, 80, 000/-. As per the details available with the department for selection of the case under CASS, following transactions ha....
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....sh deposits of Rs. 15, 26,100/-, which were not fully explained by the assessee. The assessee claimed that these deposits came from three sources: agricultural sales amounting to Rs. 9,75,000/-, a jewel loan of Rs. 2,97,500/-, and gifts of Rs. 4,00,000/- from relatives and friends on the occasion of his daughter's puppetry function. While the AO accepted the claim related to the jewel loan, which was evidenced by a valid account statement, and partly considered the agricultural income to the extent of net earnings after deducting declared expenses, the gift component of Rs. 4,00,000/- was found unsubstantiated. The assessee did not provide any gift deeds, affidavits, or documentation proving the identity, relationship, or financial capacity....