Savitha Harish Vs ITO (ITAT Bangalore)
Bangalore ITAT Restores ₹26.64 Lakh Agricultural Income Addition: Evidence Could Not Be Rejected Due to Portal Size Restrictions
.The assessee declared nil taxable income after claiming agricultural income of ₹26,64,274 as exempt. During scrutiny, she furnished details of buyers, agricultural landholdings, lease deeds, RTCs and bank statements. However, the sale invoices could not be uploaded owing to the file-size restrictions on the Income-tax portal, and permission was sought to submit physical copies.
Despite this request, the AO passed the assessment order within two days, denied the agricultural income exemption and treated the entire amount of ₹26.64 lakh as unexplained money under section 69A. The CIT(A) also rejected the additional evidence filed under Rule 46A and confirmed the addition.
The ITAT observed that documentary evidence was essential to determine the genuineness of the agricultural income. The assessee had explained during assessment itself that the invoices could not be uploaded because of portal limitations. Nevertheless, the AO completed the assessment without giving her a further opportunity, while the CIT(A) refused to admit the evidence subsequently produced.
Since several supporting documents had not been examined by the lower authorities, the Tribunal restored the matter to the jurisdictional AO for de novo adjudication after verification of the entire evidence. The AO was directed to provide the assessee a reasonable and adequate opportunity of hearing. The appeal was accordingly allowed for statistical purposes.
FULL TEXT OF THE ORDER OF ITAT BANGALORE
1. The assessee has filed the present appeal against the impugned order dated 27.01.2026, passed under section 250 of the Income Tax Act, 1961 (“the Act”) by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [“learned CIT(A)”] for the assessment year 2017-18.
