Lata Nivrutti Hake Vs ITO (ITAT Pune)
No evidence, no relief: ITAT Pune upholds addition treating agricultural receipts as unexplained income
Pune ITAT dismissed the Assessee’s appeal and upheld the addition of ₹78.70 lakh made by treating the claimed agricultural income as unexplained income.
The Assessee had filed her return declaring total income of ₹1.39 lakh and claimed substantial agricultural income from nursery activities. During scrutiny, despite issuance of notices u/s 143(2) & 142(1), no details or evidences were furnished before the AO. Consequently, the AO rejected the claim of agricultural income and added the entire amount of ₹78.70 lakh as unexplained income.
Before the CIT(A), NFAC, even after calling for a remand report, the Assessee failed to file any submissions or rebuttal, leading to confirmation of the addition. Before the ITAT also, no one appeared on behalf of the Assessee, nor was any material produced to substantiate the claim.
The Tribunal held that when no evidence is produced at any stage—before the AO, CIT(A) or the ITAT—there is no infirmity in the orders of the lower authorities. Mere assertion of agricultural income, without supporting records, cannot be accepted.
Accordingly, the ITAT confirmed the addition of ₹78.70 lakh and dismissed the appeal
FULL TEXT OF THE ORDER OF ITAT PUNE
This appeal filed by the assessee is directed against the order dated 03.01.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2017-18.
