Jigar Patel Vs ITO (ITAT Ahmedabad)
The Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, has dismissed an appeal filed by Jigar Patel, upholding an addition of Rs. 49,55,101/- made by the Income Tax Officer (ITO) as unexplained cash credit under Section 68 of the Income Tax Act, 1961. The ruling, delivered on June 26, 2025, pertains to the Assessment Year 2018-19 and affirms the decision of the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre (CIT(A)/NFAC), Delhi.
The case centered on a significant discrepancy in agricultural income declared by the assessee, Jigar Patel, for the fiscal year 2017-18, which corresponded to Assessment Year 2018-19. Mr. Patel had e-filed his return of income on July 31, 2018, declaring a total income of Rs. 5,48,790/- and an agricultural income of Rs. 75,54,376/-. His case subsequently came under scrutiny through the Computer Assisted Scrutiny Selection (CASS) system, specifically flagged under the “Agricultural Income” criteria.
During the assessment proceedings, the Assessing Officer (AO) issued several statutory notices to Mr. Patel, requesting detailed information and documentation concerning his agricultural activities. In response, Mr. Patel’s representative, Shri Shailesh C Parikh & Co. CAs, submitted a reply. However, the AO, after a thorough examination of the submitted information and the prevailing circumstances, concluded that the declared agricultural income was questionable.
