Revanasiddappa Veerasiddappa Kore Vs ITO (ITAT Bangalore)
Bangalore ITAT Restores ₹23.23-Lakh Addition: Evidence of Agricultural Income Cannot Be Rejected Without Factual Verification
The assessee, owning 49 acres and 39 guntas of irrigated ancestral agricultural land, declared gross agricultural receipts of ₹39.40 lakh, agricultural expenses of ₹8.82 lakh and net agricultural income of ₹30.58 lakh.
During demonetisation, the assessee deposited ₹11 lakh in two bank accounts and explained that the money arose from the sale of sugarcane seeds, bananas and vegetables. The AO rejected the explanation due to inconsistencies and absence of supporting bills and added the deposits as unexplained income. The AO also estimated agricultural expenditure at 40% and separately brought ₹12.23 lakh to tax as income from other sources.
Before the CIT(A), the assessee produced additional evidence, including an affidavit and crop-cultivation records issued by the Village Accountant. The CIT(A), however, refused to admit the evidence under Rule 46A and confirmed the additions.
The Bangalore ITAT held that the source of the cash deposits and the genuineness of the agricultural income required proper factual verification of the documents produced by the assessee. It therefore set aside the appellate order and restored the entire matter to the jurisdictional AO for de novo adjudication after considering the additional evidence.
