RAJBALA CHAUDHRY,AMBALA, HARYANA vs. ITO WARD-1, AMBALA, HARYANA
What did the Tribunal hold?
The Tribunal held that the AO failed to conduct adequate inquiry, such as issuing a notice under Section 133(6), to verify the genuineness of the sale of eucalyptus trees. Mere spelling mistakes or absence of certain particulars in the confirmation do not render the transaction bogus.
What were the facts?
The assessee declared agricultural income, including Rs. 21.81 Lacs from the sale of eucalyptus trees. The AO rejected this claim due to discrepancies in the purchaser's confirmation and invoice, deeming the sale non-genuine. The CIT(A) partly allowed the appeal, deleting additions related to wheat/paddy sales but upholding the addition for eucalyptus trees.
What were the issues?
Whether the AO was justified in rejecting the claim of sale of eucalyptus trees based on minor discrepancies in the supporting documents without conducting further investigation. Whether the absence of detailed expenditure proofs for agricultural income can lead to disallowance of sale receipts.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH
Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM
MANOJ KUMAR AGGARWAL (Accountant Member)
Aforesaid appeal by assessee for Assessment Year (AY) 2018-19 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 06.03.2026 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 143(3) r.w.s. 144B of the Act on 22.04.2021. The sole grievance of the assessee is confirmation of addition of agricultural income for Rs.21,81,875/-.
Having heard rival submissions and upon perusal
The order continues below.
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More judgments on Section 144B
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- Hemal Paresh Madeka, Rajkot vs Asst.Commissioner of Income Tax…ITA 955/RJT/2026[2020-21]Status: Disposed19 Oct 2026AY 2020-21
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