COMMISSIONER OF INCOME TAX Vs. JYOTI DEVI

JUDGEMENT

(1.) THIS appeal has been filed by the Revenue against the judgment of the learned Tribunal dt. 24th Sept., 2004.

(2.) THE appeal was admitted vide order dt. 9th March, 2006, by, framing the following substantial questions of law:

(3.) AGAINST this order, appeal was filed before the CIT(A) by the assessee, and the learned CIT(A) in para 5.2 has found as under: The AO had briefly discussed the reasons for initiating proceedings under Section 148 in the assessment order. It has been mentioned by him that a notice under Section 148 was issued on 26th March, 1997, as he had found that there was under -assessment of income as much as depreciation on tractors, which are agricultural implement, was claimed and allowed to the appellant whereas any deduction whatsoever if admissible, is admissible against agricultural income.