TaxTMI 
TaxTMI 
2026 (9) TMI 1307
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....learned CIT(A)"] for the assessment year 2020-21. 2. In this appeal, the assessee has raised the following grounds: - 1. The learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi has erred in partially confirming the assessment order instead of quashing the same. The order passed to the extent confirming the assessment order is bad in law and such order is liable to be quashed. 2. With out prejudice, the learned CIT(A) has erred in confirming the addition made by the Assessing Officer with respect to agricultural income amounting to Rs. 55,07,450/- on the ground that the appellant has not substantiated the agricultural income earned with documentary evidences. On proper appreciation of fac....
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....a, on account of the large agricultural income per acre shown by the assessee in comparison to the average agricultural income for the territory. Accordingly, the assessee was asked to furnish documentary details for the sale of crops, details of the APMC Mandi, documentary evidence with regard to the mode of sale of agricultural proceeds, and documentary evidence with regard to expenses such as seeds, fertilisers, pesticides, etc. In response, the assessee submitted that he has been earning agricultural income since 2001, and the same has been considered while computing the total income and tax payable thereon. It was further submitted that the agricultural crops sold during the year were maize, paddy and seeds, etc., which are grown in th....
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..../- on account of agricultural expenses were also disallowed and added to the total income of the assessee. 6. The learned CIT(A), vide impugned order, dismissed the appeal filed by the assessee and held that absence of documentary evidence to prove the sale of agricultural produces creates serious doubt about the genuineness of the claim, as the assessee has not even furnished details of persons to whom agricultural produce was allegedly sold, such as their names, address, quantity sold, price realised, etc. Further, as regards the agricultural expenses amounting to Rs. 5,87,037/-, the learned CIT(A) held that the assessee has not produced a single bill, receipt, voucher or any other documentary evidence to prove the actual incurring of ....
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....dingly, the learned AR submitted that, given an opportunity, the assessee shall furnish all the details in support of its claim for agricultural income earned from the agricultural farms and nursery in the East Godavari River Belt of Andhra Pradesh, and the agricultural expenditure incurred during the year. 8. On the other hand, the learned Departmental Representative, by vehemently relying upon the order passed by the lower authorities, submitted that despite the grant of ample opportunity, the assessee failed to submit any of the details to substantiate its claim before the lower authorities. 9. We have considered the submissions of both sides and perused the material available on record. As per the assessee, it has agricultural lan....
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....18-19, the agricultural income claimed to have been earned by the assessee was disallowed @20% following the approach adopted in the preceding year. As the assessment order was passed under section 144 of the Act, the learned CIT(A), inter alia, restored the issue of disallowance of agricultural income earned by the assessee to the file of the AO for fresh adjudication. We find that vide order dated 13.05.2025 giving effect to the order passed by the learned CIT(A) for the assessment year 2018-19, the addition on account of disallowance of agricultural income was deleted by the AO after considering documentary evidence furnished by the assessee, such as pertaining to ownership, agricultural receipts and expenditure proofs substantiating agr....