Arjan Lila Goraniya Vs ITO (ITAT Rajkot)
Farmer Wins Against Unexplained Investment- Consistency Applied: When Brother’s Addition Deleted, Assessee Also Gets Relief- Compensation from Reliance Infrastructure Accepted as Source – ITAT Grants Full Relief
Introduction
This case involves an appeal filed by Arjan Lila Goraniya against the Assessing Officer’s (AO) addition of Rs. 65,20,805, treated as unexplained investment under section 69 of the Income Tax Act, 1961. The appellant challenged the order of the CIT(A), which had upheld the addition based on the assessee’s alleged unexplained investment in the purchase of agricultural land. The appeal was adjudicated by the Income Tax Appellate Tribunal (ITAT), Rajkot Bench, with Dr. Arjun Lal Saini serving as the Presiding Member.
Background and Factual Matrix
The core issue in this case pertains to the treatment of Rs. 65,20,805 invested by the appellant in the purchase of agricultural land at Visavada Village, Taluka Porbandar, through a joint purchase agreement dated April 27, 2012. The land was acquired from Reliance Industries Limited through a compulsory acquisition process by the Gujarat Government, which necessitated the assessment of the source of the investment made in the land. The land was purchased in partnership with a co-owner, Mr. Arjanbhai Lilabhai Goraniya, with both holding an equitable 50% share.
