Chander Pal Vs ITO (ITAT Delhi)
In Chander Pal Vs ITO, the ITAT Delhi allowed the appeal of the assessee and directed deletion of an addition of Rs.15,50,000/- made under Section 69A of the Income Tax Act for Assessment Year 2017-18.
The assessee, an agriculturist, had filed a return of income declaring agricultural income of Rs.20,50,000/-. Before the Tribunal, the assessee contended that due to an inadvertent mistake, agricultural income was wrongly declared at Rs.20,50,000/- instead of Rs.10,50,000/-. To support this contention, the assessee filed an affidavit of Shri Manish Kumar, who had purportedly filed the return of income on behalf of the assessee.
The assessee further submitted that the Assessing Officer had estimated agricultural income at only Rs.5,00,000/- by considering income from wheat crop alone. According to the assessee, agricultural operations were carried out throughout the year and income was also earned from cultivation of paddy. Reliance was placed on khasra girdawari records to show cultivation of both Rabi and Kharif crops. The assessee also pointed out that agricultural income declared in subsequent assessment years, namely Rs.14,78,195/- in AY 2018-19 and Rs.12,87,760/- in AY 2019-20, had been accepted by the Department.
The Department supported the order of the lower authorities and opposed the appeal.
