TaxTMI 
TaxTMI 
2026 (1) TMI 691
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....s) ('CIT(A)'), dated 08.09.2025, which in turn arises out of an assessment order passed by Assessing Officer u/s. 143(3) read with sections 143(3A) & 143(3B) of the Act, on 16.04.2021. 2. Grounds of the appeal raised by the assessee are as under: 1. The Learned Commissioner of Income-tax (Appeals)- NFAC, Delhi erred in confirming the action of the assessing officer in making addition of Rs. 26,61,729/- by way of excess agriculture income, being difference between the gross agriculture receipts shown by the Appellant at Rs. 32,61,729/- and estimated by the A.O. at Rs. 6,00,000/-. 2. The Learned Commissioner of Income-tax (Appeals)- NFAC, Delhi erred in confirming the action of the assessing officer in estimating agricult....
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....ssessing officer, the assessee submitted statement of computation of income, details of land, details of agricultural products etc. On perusal of the return of income filed for AY 2017-18, it was noticed by the assessing officer, that the assessee has claimed agriculture income at Rs. 14.76 lac, whereas agricultural income for AY 2018-19 which is declared at Rs. 32.61 lacs as compared to last year. The assessee, therefore, vide notice u/s. 142(1) of the Act, dated 27.12.2020 was asked to explain reason for substantial increase in the agricultural income in A.Y.2017-18, in comparison to A.Y. 2018-19, (inspite of the total agricultural land area remaining the same) alongwith supporting documentary evidence. The assessee did not produce any ev....
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....osition that the assessee failed to substantiate its claim satisfactorily. The documents filed were sketchy, and crucially, no verifiable proof of irrigation facilities or scientific basis for higher yield was furnished. The 7/12 extracts produced showed that the land was largely unirrigated, whereas the assessee claimed to have grown high-value crops such as cotton and jeera, which typically require assured irrigation. This inconsistency itself casts doubt on the genuineness of the claim. Therefore, based on this factual position, the learned CIT (A) confirmed the addition made by the assessing officer. 9. Aggrieved by the order of the ld. CIT(A), the assessee is in appeal before this Tribunal. 10. Ms. Devina Patel, begins by pointin....
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....materials brought on record. I note that total agricultural income shown in the income tax return (ITR) was to the tune of Rs. 32,61,729/-, which was gross agricultural income. As per assessee, the agricultural expenses amounting to Rs. 10,93,636/- were not claimed while filing return of income through oversight. It was due to oversight that the return preparer did not fill up the details of agricultural expenses in the return of income due to which gross agricultural income was only shown therein and therefore if compared with previous year, assessee showed excess agriculture income, in the return of income, which the assessing officer denied to accept and restricted the agricultural income to the tune of Rs. 6,00,000/-. 14. Under secti....
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....in the submissions, advanced by the learned Counsel for the assessee and evidences submitted before the lower authorities, such as proof of land holding, evidence showing agricultural activities etc, therefore, assessee deserves relief, however, full relief cannot be granted. 15. Considering the above factual position, I note that assessing officer has accepted that assessee was doing agricultural activities, and the dispute is only with regard to gross agricultural income. The gross agricultural income shown in the income tax return is more than the previous year's return of income. I also note that assessee has been showing agricultural income constantly since last so many years and therefore considering these facts, I am of the view t....