Dismissing the appeal of the assessee the Court held that the Tribunal had recorded the finding that the assessee was neither in possession of the agricultural land nor did he perform any agricultural activity. Therefore, the question of earning any agricultural income did not arise. These findings were pure findings of fact which had been recorded on meticulous appreciation of evidence on record. The findings had not been shown to be perverse . ( AY. 2005-06)
Jinesh (HUF) v. ITO (2021) 431 ITR 588 / 278 Taxman 369 (Karn)(HC )
S.143(3): Assessment -Income from undisclosed sources —Agricultural income-Land taken on lease – Amount Shown -No agricultural operations had been carried on in land -Addition is held to be justified [S.10(1)]