Sonu Goma Bhangale Vs ITO (ITAT Pune)
Assessee, an individual, did not file return for AY 2010-11. Based on cash deposits of Rs.42,64,155/- in Godavari Laxmi Co-op Bank, notice u/s 148 was issued. Assessee filed return declaring Rs.1,25,840/- as income & agricultural income of Rs.65,00,000/-. AO completed reassessment u/s 143(3) r.w.s.147 accepting the returned figures. Subsequently, PCIT revised this order u/s 263 on 30.03.2020 directing AO to verify the source of cash deposits & agricultural income claim. AO thereafter framed order u/s 147 r.w.s.263 making addition of Rs.47,57,055/- as unexplained cash credits & assessed income at Rs.48,82,895/-.
CIT(A) upheld the addition, holding that the claim of agricultural income was unsubstantiated. The order notes that assessee produced handwritten slips without dates, signatures or addresses, furnished no quantitative details of banana/cotton yield, & failed to submit any bills or vouchers for seeds, fertilizers, labour, irrigation or transportation. CIT(A) also noted no linkage between alleged agricultural receipts & bank deposits. The claimed Rs.10 lakh land-advance was held inconsistent & unproved. CIT(A) found repeated non-compliance of notices u/s 142(1) & confirmed invocation of section 68.
Before Tribunal, Assessee submitted that complete details—cash deposit/withdrawal summary, agricultural land documents (7/12 extract), & sale proceeds—were already furnished but not properly verified by AO despite explicit directions in the 263 order. Tribunal noted that the matter had undergone two rounds of assessment & a 263 revision, but AO still did not meaningfully verify agricultural operations, land holding, crop yield, cash flow pattern or the peak credit. Tribunal observed that even CIT(A) failed to evaluate these facts in a proper manner.
