Section 68 of Income Tax Act, 1961—In the instant case, appeal of assessee against the order passed by ITAT whrein tribunal held that appellant is under no obligation to explain the “source of income”?

Held that— As regards the claim of Rs. 14,87,543/as accumulated savings and agricultural income, I am of the view that since the assessee was having some agricultural income, an amount of Rs. 5,00,000/can at best be treated as explained. To this extent, I uphold the plea of the assessee.

Having heard the learned counsel appearing for the appellant and having gone through the materials on record, more particularly, the findings of fact recorded by the appellate tribunal, we see no good reason to disturb the impugned order. In our view, none of the questions as proposed can be termed as the substantial questions of law.[SHIVRAM RAMCHANDBHAI PATEL VERSUS INCOME TAX OFFICER][2019] 16 ITCD Online (21) [GUJARAT HIGH COURT]