ITAT Bangalore: Assessee Gets 90 Days to Prove Agricultural Source of Disputed Bank Deposits

Shivashankrappa Sahukar Vs ITO (ITAT Bangalore)

Fifty-Four Acres of Farmland, but Where Is the Crop Income? ITAT Sends Cash Deposits Back for Verification

The deposits and the agricultural explanation

The Assessing Officer (AO) received information about substantial transactions in the bank accounts of Shivashankrappa Sahukar for assessment year 2015–16. Reassessment proceedings followed, and the AO ultimately treated ₹50,99,684 of bank credits as unexplained, rejecting the explanation that the money came from agricultural income, earlier bank withdrawals and accumulated savings.

Sahukar said that he owned 54 acres of irrigated ancestral agricultural land in the villages of Arshinagi and Hemnal. He produced land records and stated that buyers collected produce from his farm and paid cash there. The AO sought supporting details of the crops, cultivation expenditure, production and sales. Finding the evidence insufficient, he made the addition. The CIT(A) upheld it.

Before the Bangalore ITAT, the assessee attacked both the validity of the reopening and the addition on merits. He succeeded in obtaining another opportunity to prove the source of the deposits, but his challenges to the reassessment itself failed.

A digital signature after midnight

One objection concerned the Section 148 notice. It was dated 30 March 2022 but digitally signed at 12:33 a.m. on 31 March 2022. The assessee argued that this made the notice invalid.