Case Law Details
Ravindra Dattu Jadhav Vs ITO (ITAT Pune)
Introduction: The case of Ravindra Dattu Jadhav vs. ITO, heard at ITAT Pune, involves an individual engaged in small-scale land trading and agricultural activities. The Assessing Officer treated a significant bank deposit as undisclosed income, leading to a dispute. The CIT(A) partially upheld the addition, prompting the appellant to approach ITAT Pune for relief.
Detailed Analysis: Ravindra Dattu Jadhav, involved in land trading and assisting his parents in running a tea shop, also undertakes agricultural activities on rented land. The Assessing Officer flagged a bank deposit of Rs.47,20,000 as undisclosed income. The appellant explained that the amount originated from prior bank withdrawals, agricultural income, and represented business turnover.
The CIT(A) acknowledged the appellant’s ability to justify certain cash deposits but found a portion inadequately substantiated. He accepted explanations for Rs.21,40,000, attributed to prior withdrawals and refunded advances. However, the remaining Rs.25,80,000, allegedly comprising gross agricultural income and turnover from land transactions, faced skepticism. The CIT(A) doubted the appellant’s agricultural involvement, asserting that possession of agricultural land was insufficient for claimed net income of Rs.28 lakhs.
Despite the appellant furnishing bills supporting agricultural produce sales, the AO dismissed them as sourced from a nonexistent merchant. The CIT(A) failed to consider the appellant’s agricultural activity adequately. While the appellant asserted that advances from customers were refunded before year-end, no verification occurred.
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