₹8.92 Lakh Agricultural Income from 20 Acres Reasonable: ITAT Ranchi

Kalpana Devi Vs ITO (ITAT Ranchi)

₹8.92 Lakh Agricultural Income from 20 Acres Reasonable: Earlier-Year Acceptance and Comparable ITAT Ruling Cannot Be Ignored: ITAT Ranchi

Summary: The Ranchi Bench of the Income Tax Appellate Tribunal has allowed an assessee’s claim of ₹8,91,570 as exempt agricultural income from approximately 20 acres of agricultural land.

The Tribunal noted that in the immediately preceding assessment year, the CIT(A) had accepted agricultural income of ₹8 lakh from the same landholding. Further, in another case relating to the same assessment year, the Ranchi Tribunal had estimated agricultural income at ₹1 lakh per acre. Considering these facts, the assessee’s disclosure of about ₹44,579 per acre was held to be reasonable.

The decision was rendered in Kalpana Devi v. ITO, Ward-3(1), Deoghar, ITA No. 72/Ran/2026, Assessment Year 2012-13, order dated 10 September 2026.

Facts of the case

The assessee had disclosed agricultural income of ₹8,91,570 and claimed it as exempt under Section 10(1) of the Income Tax Act.

The assessment was reopened under Section 147. According to the Assessing Officer, the assessee had shown substantial agricultural income as exempt, but had not produced satisfactory evidence supporting such income in the assessment records.

The Assessing Officer completed the reassessment under Section 144 read with Section 147 through an order dated 10 December 2018 and denied the exemption claimed under Section 10(1). The agricultural income was consequently treated as income from other sources.