Parshotmbhai Patel Vs ITO (ITAT Ahmedabad)
The Income Tax Appellate Tribunal (ITAT), Ahmedabad, allowed the assessee’s appeal against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), for Assessment Year 2020-21. The dispute concerned an addition of ₹31,76,222 made under Section 69A of the Income-tax Act towards alleged unexplained agricultural income and its taxation under Section 115BBE.
The assessee had filed a return declaring total income of ₹5,72,650. The case was selected for scrutiny on the issue of agricultural income. During the assessment, the Assessing Officer treated agricultural receipts of ₹35,76,222 as unexplained money under Section 69A. The assessee’s appeal before the CIT(A) was dismissed.
Before the Tribunal, the assessee submitted that he was a farmer who had consistently disclosed agricultural income in earlier years. He contended that all supporting evidence had been furnished during the assessment proceedings, including bank statements showing agricultural receipts, agricultural sale bills, Uttara No. 7/12 extract, Gam Namuno 8A, Hak Patrak-6 (land ledger), and proof of sale of agricultural produce under the Government’s Minimum Support Price scheme to Government State Civil Supply Ltd. The assessee also pointed to bank credits received from the relevant Gujarat Government agency and argued that these documents had been ignored by both the Assessing Officer and the CIT(A). The Revenue maintained that the assessee had failed to establish that the receipts represented agricultural income.
