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| The Tax Publishers2019 TaxPub(DT) 8310 (Jp-Trib) INCOME TAX ACT, 1961
Section 68
Where CIT(A) had taken a reasonable percentage of 15% expenditure of gross agricultural income and that too agricultural income from agricultural operations excluding income from sale of trees, considering facts of case and prevailing market conditions in agricultural sector, no infirmity was there in order of CIT(A).
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Income from undisclosed sources - Addition under section 68 - CIT(A) reasonably estimated taxable agriculture income shown by assessee as per facts of case -
Issue as regards agricultural income, which was treated as undisclosed income by CIT(A) arose for consideration. Held: Issue involved in assessee's appeal was identical as in case of sister concern in Gullu Mal Gulachi Developers (P.) Ltd. v. ITO ([ITA No. 868/JP/2019, dt. 1-11-2019]). CIT(A) had taken a reasonable percentage of 15% expenditure of gross agricultural income and that too, agricultural income from agricultural operations excluding income from sale of trees. In facts and circumstances of case as well as prevailing conditions in the agricultural sector, claim of assessee could not be accepted. Thus, CIT(A) had taken a reasonable view in estimating expenditure at 15%, there was no error or illegality in order of CIT(A) in estimating the expenditure @ 15% of gross agricultural income.
REFERRED :
FAVOUR : Against the assessee
A.Y. : 2015-16
IN THE ITAT, JAIPUR BENCH
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