Manjula Vs ITO (ITAT Chennai)
Agricultural Income Must Be Judged on Official Records, Not Satellite Images-₹1.03 Cr Addition on Cash Deposits Set Aside – Matter Restored to AO-ITAT Chennai Rejects Google Earth Data – Accepts Casuarina Crop Evidence
Assessee, an individual, had not filed return originally. AO reopened assessment after noticing cash deposits of ₹1,12,46,000 & time deposits of ₹20,99,384. In response, Assessee explained that she was a seasonal agriculturist cultivating Casuarina on 31 acres, realising ₹93 lakhs from harvest in April 2016, before demonetisation. Tahsildar issued an income certificate & revenue records were furnished. AO, however, rejected the claim relying on Google Earth Pro images, and restricted agricultural income to ₹15.5 lakhs, adding balance ₹1,02,96,000 u/s 69A as unexplained.
CIT(A)/NFAC confirmed the addition stating that no proper evidence was furnished.
Before ITAT, Assessee argued that AO himself obtained a report from Dean of Forestry, TNAU, Mettupalayam, who estimated Casuarina income at ₹67 lakhs, but AO wrongly ignored it. It was contended that authenticated certificates from Tahsildar & Dean cannot be brushed aside in favour of unverified Google Earth images.
Tribunal agreed, holding that official certificates & expert reports carry more evidentiary weight than satellite imagery. It observed that AO erred in disregarding these authenticated records. Accordingly, ITAT set aside orders of AO & CIT(A), and directed AO to pass fresh assessment based on the Dean’s report, after granting reasonable opportunity to Assessee.
