Sanjay Jayantibhai Patel Vs ITO (ITAT Ahmedabad)
Income Tax Appellate Tribunal (ITAT) Ahmedabad reviewed the case of Sanjay Jayantibhai Patel vs. ITO, concerning a discrepancy in the assessee’s reported agricultural income for the Assessment Year 2020-21. The assessee initially declared ₹64.68 lakh as agricultural income but later corrected it to ₹20 lakh, citing a calculation error. The National Faceless Appeal Centre (NFAC) upheld the addition of ₹64.68 lakh under Section 68 of the Income-tax Act, 1961. The ITAT noted that the Revenue had not thoroughly examined the actual agricultural operations undertaken by the assessee to verify income generation. The tribunal ruled that in the interest of justice, the matter should be remanded to the Assessing Officer for a detailed review of the agricultural activities and supporting documentation.
The ITAT emphasized that a proper assessment of the agricultural income was necessary before confirming the addition under Section 68. The assessee’s counsel argued that sufficient evidence, including bank statements, was available to substantiate the corrected income figure. Acknowledging this, the tribunal allowed the appeal for statistical purposes, directing the tax authorities to reassess the case by verifying the legitimacy of agricultural income claims. The order, dictated and pronounced in open court on December 3, 2024, underscores the importance of a thorough examination of tax-related disputes, particularly concerning agricultural income declarations.
