Machamada Ponnappa Prakash Vs ITO (ITAT Bangalore)
ITAT Bangalore: Agricultural Income Evidence Cannot Be Ignored-Matter Remanded for Fresh Verification
The Bangalore ITAT dealt with an addition made under Section 69A treating bank deposits of ₹85.71 lakh as unexplained money, where the assessee claimed the same as agricultural income. The AO and CIT(A) rejected the claim primarily due to lack of supporting evidence during assessment proceedings.
Before the Tribunal, the assessee furnished detailed additional evidence, including landholding records (about 55 acres owned + leased land), sale invoices of agricultural produce (coffee, pepper, arecanut), and bank statements showing RTGS receipts matching such invoices. The Tribunal noted that entries in bank statements tallied with invoices, establishing a prima facie nexus between deposits and agricultural activities.
It also observed that similar agricultural income had been accepted by the department in earlier years, and such consistency cannot be ignored without contrary evidence.
However, since certain supporting documents (like expense details, labour payments, etc.) were not furnished before the AO earlier, the Tribunal held that complete verification was required. Accordingly, the matter was remanded back to the AO for fresh examination, directing him to consider all evidences and past assessments.
Thus, while recognizing the credibility of the assessee’s claim, the ITAT restored the issue for proper verification, and the appeal was partly allowed for statistical purposes.
FULL TEXT OF THE ORDER OF ITAT BANGALORE
