Balakrishnamurthy Ramachandrababu Vs DCIT (ITAT Bangalore Bench)
APMC Bills Harvest Relief u/s 69A: Agricultural Sale Proceeds Cannot Be Uprooted Merely Because RTC Does Not Mention the Crop
Summary: The assessee, an individual deriving income from salary & other sources, filed his return of income for AY 2022-23. His case was selected for scrutiny to verify, inter alia, large cash deposits in his bank account & certain reported transactions relating to purchase/sale of immovable property.
During assessment proceedings, the assessee denied having undertaken any property transaction during the relevant year. On verification of the records, the AO accepted the explanation & did not make any addition on that issue.
Agricultural Produce Sold Through APMC
The assessee explained that he owned 4 acres & 4 guntas of ancestral agricultural land, where he cultivated vegetables & fruits. The agricultural produce was sold through the APMC Yard, Doddaballapura, and the sale proceeds received in cash were deposited in his bank account.
In support of the explanation, the assessee furnished:
- RTC & pahani records relating to the agricultural lands;
- monthly summaries of agricultural sales;
- sale bills issued through the APMC Yard; &
- copies of the relevant bank statements.
The assessee further explained that, since agricultural income was exempt from tax, he was under a bona fide but mistaken belief that such income need not be disclosed in the return.
