2022 (6) TMI 1234 - AT - Income Tax

Tribunal overturns disallowance of agricultural expenses, citing lack of valid reasons.

M/s. Shrikrishna Khandsari Sugar Mills Versus ITO, Ward-1, Dhule

M/s. Shrikrishna Khandsari Sugar Mills Versus ITO, Ward-1, Dhule - TMI Issues:Confirmation of disallowance of agricultural expenses by Assessing Officer.Analysis:The appeal was against the confirmation of disallowance of Rs.4,19,970/- made by the Assessing Officer in relation to agricultural expenses for the assessment year 2014-15. The assessee, engaged in manufacturing, trading in Khandsari sugar and jaggery, and power generation, declared gross agricultural receipts of Rs.47,78,862/- and agricultural expenses of Rs.12,52,631/-. The AO increased the expenses to Rs.16,72,601/- based on a general market trend of 35% of gross agricultural income, resulting in the disallowance. The CIT(A) upheld the disallowance, leading to the appeal before the Tribunal.The Tribunal noted that the assessee's declared agricultural expenses accounted for over 26% of the gross receipts, with detailed year-wise figures provided. The AO's rejection of the expenses as lower based on a 35% trend without valid reasons was deemed unjustified. The Tribunal found that the assessee maintained complete and unchallenged details of agricultural expenses. Since the AO failed to provide plausible reasons for rejecting the expenses or to make a best judgment on a rational basis, the disallowance was deemed ad hoc and unjustified. Consequently, the Tribunal directed the deletion of the disallowance, concluding that the authorities were not justified in their decision.In conclusion, the Tribunal allowed the appeal, setting aside the disallowance of agricultural expenses made by the Assessing Officer. The order was pronounced in the Open Court on 20th June, 2022.