2025 (12) TMI 973

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.... 69A of the Income Tax Act, though I had fully explained the source of cash deposits with proper evidence 2. The Ld. IT(A) has not accepted my opening cash balance of 6,16,285/- though the same was duly carried forward from earlier year and reflected in my cash book. The Ld. CIT(A) has restricted my agricultural income to 2,70,000/- only on estimate basis, ignoring land records, Rin Pustika, and sale bills of agricultural produce submitted by me. 4. The Ld. CIT(A) has failed to appreciate that I had sufficient explained sources consisting of agricultural income, rental income, gifts from my father, and opening cash balance, which together fully explain the deposits. 5. The orders passed are unjust, arbitr....

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....oner of Income Tax, ITAT, Raipur vide office letter in F. No. Jt. CITITAT/ RPR/Report/2025-26 dated 21.11.2025, it is found from the documents of the assessee's cash flow statement, books of accounts, agricultural receipts/documents furnished by the assessee has been thoroughly examined by this office and found correct. In respect of the opening cash balance of Rs. 6,16,285/- is brought forward from FY-2015-16 which is not income of the current year i.c. FY-2016-17 relevant to AY-2017-18." 5. Ld. Sr. DR fairly supported the findings of the jurisdictional AO and submitted that as examined by the office of the AO everything was found correct with regard to opening cash balance of Rs. 6,16,285/-. 6. That as discernable from the afore....

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....le bills of agricultural produce dated 7.04.2016, Rs 1,56,800/-, Rs 2,08,000/- and Rs 1,98,400/- respectively. Thus, sale bills for Rs 10,01,400/- has been produced by appellant. However, no details with regard to agricultural expenditure incurred have been furnished. It can not be a case where agricultural income is earned without incurring any expenditure. Therefore, entire sale proceeds cannot be considered to have formed source for cash deposits in the bank account. Further, in cash book reproduced above, the appellant has not recorded any expenditure incurred in cash for carrying out agricultural operations except Rs 2,985/- on 11.07.2016. It is not the case of the appellant that entire agricultural expenditure is incurred through bank....

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....Rs. 11,00,996 (-) Rs. 2,70,000/-) remains unexplained" 8. That vide aforestated finding, the Ld. CIT(A)/NFAC determined the net agricultural income in the hands of the assessee at Rs. 2,70,000/- against the claim of the assessee that he was having agricultural income at Rs. 11,00,996/-, accordingly the Ld. CIT(A)/NFAC had added Rs. 8,30,996/- as un-explained cash deposits in the hands of the assessee. 9. Similarly, Ld. Sr. DR as directed by this Bench had obtained a report from the AO dated 02.12.2025 and submitted that said agricultural income of Rs. 11,00,996/- has been verified from the documents furnished by the assessee i.e. Rin Pustika, Mandi Receipts etc. and therein it did reflect cultivation of own land. That on the basis of ....