Vinubhai Keshavbhai Rabadiya Vs ITO (ITAT Surat)
Huge Agricultural Income Accepted as Genuine – No Contrary Evidence from AO – Onus Discharged, Addition Unsustainable
Assessee declared agricultural income of ₹26,20,240 for AY 2016-17, compared to ₹4,04,995 in preceding year. AO treated ₹20,65,295 as unexplained “excess” agricultural income & disallowed expenses, alleging inflated claim. CIT(A) confirmed the addition.
Before Tribunal, Assessee explained that agricultural land was jointly held with family members; in the relevant year, brother did not take his share, resulting in higher agricultural receipts being reflected entirely in Assessee’s hands. Assessee produced land records, details of crops (sugarcane), sale bills to Sahakari Mandali, expense vouchers, and previous year’s bifurcation. Tribunal noted that none of these facts were disputed by AO or CIT(A).
Tribunal held that merely because income increased substantially, it cannot be rejected when documentary evidences substantiate cultivation, yield & sale. Observation of CIT(A) that vouchers were “self-made” was found unjustified since expenses were supported and directly linked to cash-crop cultivation. As the entire agricultural activity stood proved & revenue brought no contrary material, Tribunal deleted the entire addition & allowed appeal.
FULL TEXT OF THE ORDER OF ITAT SURAT
This appeal is filed by the Assessee against the order dated 12.03.2025 passed by the Addl/JCIT(A)-8, Mumbai [hereinafter referred to as “CIT(A)” for short] u/s 250 of the Income-tax Act, 1961 [hereinafter referred to as “the Act” for short] for Assessment Year 2016-17.
