The assessee, an individual, declared total income of Rs.1,79,160/- and agricultural income of Rs.3,00,000/- for A.Y. 2017-18. During scrutiny assessment, the Assessing Officer noticed cash deposits aggregating to Rs.85,93,000/- during the demonetisation period, unsecured loans of Rs.9,25,90,050/-, sundry creditors of Rs.1,07,25,456/- and agricultural income of Rs.3,00,000/-, which the assessee failed to substantiate with requisite documentary evidence. Additions aggregating to Rs.11,22,08,506/- were accordingly made under section 143(3), which were confirmed by the CIT(A). Before the Tribunal, the assessee sought one final opportunity to substantiate the claims before the Assessing Officer and undertook to plant 500 trees with the assistance of the specified NGO, or alternatively deposit the requisite cost towards plantation, installation, protection and maintenance of the trees. The Tribunal, considering the facts and in the interest of justice, restored the matter to the file of the Assessing Officer for limited verification, subject to the condition that the assessee should, within one month from the date of the order, plant 500 trees and furnish documentary evidence thereof, or deposit the requisite cost with the NGO. It was held that the relief was strictly conditional and, in case of failure to comply within the stipulated period, the order of the CIT(A) would stand restored and the appeal would stand dismissed. Subject to compliance, the appeal was allowed for statistical purposes.( AY. 2017 -18 ) ( ITA No. 1413/CHD/2026 dt. 14 -8 -2026 )
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