Venkatachalam Elangovan Vs ITO (ITAT Chennai)
Chennai ITAT: Agricultural Income Claim Cannot Be Rejected Without Fair Opportunity to Produce Evidence
The Chennai ITAT set aside the orders of the CIT(A) confirming additions under section 69A in respect of agricultural income claimed as exempt under section 10(1). The Assessing Officer had treated the assessee’s agricultural income as unexplained money on the ground that, although land records (Chitta/Adangal) were furnished, the assessee failed to produce complete evidence regarding agricultural operations, income and expenditure. The CIT(A) upheld the addition, noting that the assessee had failed to effectively prosecute the appeal.
The Tribunal held that, in the interests of natural justice, the assessee should be afforded one more opportunity to substantiate the claim of agricultural income with supporting evidence. Accordingly, it set aside the orders of the CIT(A) for both assessment years and restored the matters for fresh adjudication, directing the CIT(A) to decide the appeals on merits after granting a reasonable opportunity of hearing. The assessee was also directed to cooperate and furnish all relevant evidence in support of the claim.
FULL TEXT OF THE ORDER OF ITAT BANGALORE
The captioned appeals filed by the Assessee are directed against the orders of the Ld. Commissioner of Income Tax (Appeals), NFAC, Delhi, [CIT(A)] both dated 12.12.2025 for Assessment Years (AYs) 2020-21 and 2021-22.
