ITAT Rules Entire Declared Income as Agricultural, Including Disputed Amount, Favoring the Assessee's Appeal.

The ITAT allowed the appeal of the assessee, determining that the declared income of Rs. 15,84,000 should be classified as agricultural income. This decision was based on the AO's prior acceptance during tax computation. Consequently, the ITAT held that the entire amount, including the disputed Rs. 8,84,000, should be considered agricultural income, thus favoring the assessee.

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Issues Involved:
The judgment involves the assessment of agricultural income and cash deposits during the demonetization period, with a focus on whether the income declared by the assessee is genuine and supported by evidence.

Assessment of Agricultural Income:
The assessee filed a return of income declaring total income, including agricultural income. However, during scrutiny, the assessee failed to provide sufficient evidence to support the declared agricultural income of Rs. 15,84,000. The Assessing Officer (AO) treated the agricultural income as unexplained money u/s 69A and also questioned a cash deposit of Rs. 2 lakhs during demonetization. The CIT(Appeals) partially allowed the appeal, granting relief of Rs. 7 lakhs but confirming the balance amount of Rs. 8,84,000 as income. The ITAT, after considering submissions, noted that the AO had accepted the income as agricultural income during tax computation. Therefore, the ITAT held that the entire declared income should be considered as agricultural income and allowed the appeal of the assessee.

Cash Deposits during Demonetization:
The dispute also involved cash deposits made during the demonetization period. The assessee submitted details of sales receipts for mangoes grown on agricultural land, but the revenue authorities did not accept the evidence. The ITAT considered the submissions, including the types of mangoes sold and the lack of external bills due to direct sales to the public. The ITAT noted that the AO was satisfied with the cash deposits and did not make any additions. Ultimately, the ITAT concluded that the main source of agricultural income was from mango sales, which should be treated as agricultural income subject to normal tax rates.

Conclusion:
The ITAT allowed the appeal of the assessee, emphasizing that the declared income of Rs. 15,84,000 should be considered as agricultural income based on the AO's acceptance during tax computation. The ITAT held that the entire amount, including the balance of Rs. 8,84,000, should be treated as agricultural income, leading to the allowance of the appeal.

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