Agricultural receipts proved by records were not unexplained money, so the addition and special-rate tax treatment failed.

Agricultural receipts supported by land records, bills, bank entries and prior acceptance of similar income could not be treated as unexplained money. The ITAT Ahmedabad held that the evidentiary record established the agricultural character of the receipts, and the addition under section 69A was unsustainable. Consequential taxation under section 115BBE also could not be maintained. Rejection of the claim merely because the assessee revised the computation of income was found insufficient to displace the documentary proof. The appeal was allowed in favour of the assessee.

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Issues: Whether the addition made as unexplained money in respect of agricultural receipts and the consequential taxation under the special rate provision could be sustained when the assessee produced land records, bills, bank entries and past acceptance of agricultural income.

Analysis: The assessee furnished supporting material showing ownership and cultivation of agricultural land, details of agricultural bills, and bank statements reflecting receipt of sale proceeds. The record also indicated that similar agricultural income had been accepted in earlier years. On these facts, the rejection of the claim merely because the assessee had revised the computation of income was found unsustainable. The evidentiary material was sufficient to establish the agricultural character of the receipts, and the addition was not supported on the footing of unexplained money.

Conclusion: The addition under section 69A of the Income-tax Act, 1961 did not survive, and the consequential tax treatment under section 115BBE of the Income-tax Act, 1961 was not upheld. The appeal was allowed in favour of the assessee.

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