SATVIK FARMS,KOLKATA vs. ITO, WARD 36(1), KOLKATA

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ITA 2606/KOL/2025Status: DisposedITAT Kolkata01 September 2026AY 2020-20213 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found that an amended Khatoni, submitted by the assessee, showed no difference in the number of fruit trees compared to the assessee's statement. Therefore, the addition made by the AO was deleted.

What were the facts?

The assessee, an agriculturist, declared nil total income and substantial agricultural income. The AO made an addition of Rs. 6,43,344/- on account of alleged excess fruit sales, finding discrepancies in the number of fruit-bearing trees as per the Khatoni and the assessee's statement.

What were the issues?

Whether the addition on account of excess fruit sales was justified based on discrepancies in the number of fruit-bearing trees, and if an amended Khatoni should be considered.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B

AI-generated summary — verify with the full judgment below

आयकर अपील�य अ�धकरण, कोलकाता पीठ “एसएमसी’’, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH: KOLKATA �ी राजेशकुमार, लेखा सट�य के सम� [Before Shri Rajesh Kumar, Accountant Member] I.T.A. No.2606/Kol/2025 Assessment Year: 2020-21 Satvik Farms Vs. ITO, Ward-36(1), Kolkata

(PAN: ACLFS 7618 B) ( अपीलाथ� ) Respondent / ��यथ� Appellant / Date of Hearing / सुनवाई 08.07.2026 क� �त�थ Date of Pronouncement/ 01.09.2026 आदेश उ�घोषणा क� �त�थ For the Appellant/ Shri Rajkumar Agarwal, AR �नधा�रती क� ओर से For the Respondent/ Smt. Pampa Ray, Sr. DR राज�व क� ओर से

ORDER / आदेश

This is an appeal preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-NFAC, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 19.09.2025 for the AY 2020-21. 2. The only issue raised by the assessee is against the order of Ld. CIT(A) confirming the addition of Rs. 6,43,344/- as income from other sources. 3. Facts in brief are that the assessee is an agriculturist and furnished the return of income on 25.12.2020 declaring total income nil and agricultural income of Rs.

2 I.T.A. No.2606/Kol/2025 Assessment Year: 2020-21 Satvik Farms 35,86,725/-. The case of the assessee was selected for limited scrutiny for examination of agricultural income. Accordingly statutory notices along with questionnaire were issued which were duly replied by the assessee. The AO on the basis of evidences furnished by the assessee noted that the sale of product like fruits, vegetables, bajra, wheat etc. being remained unverified partly as the invoices submitted by the assessee did not have PAN or GST. Accordingly, the AO noted that the fruit bearing trees mentioned in Khatoni and details submitted by the assessee were not matching. The AO noted that the assessee has shown excess number of trees. The AO compared the trees and calculated the amount received from sale of fruit at Rs. 13,80,586/- on the basis of number of fruit trees as per the Khatoniand the statement of assessee and then proportionately computed the excess fruit salesat Rs. 6,43,344/- and added the same to the income of the assessee. The AO hasalso added Rs. 19,13,121/- for sale of vegetables in the assessment framed u/s 143(3) read with Section 144B of the act dated 27.09.2022.

4.

In the appellate proceedings, the Ld. CIT(A) partly allowed the appeal of the assessee by deleting the addition in respect of vegetable of Rs. 19,13,121/- and sustaining the addition of Rs. 6,43,344/- in respect of fruit sales. Hence the assessee is in appeal before us.

5.

We have heard the rival contentions and perused the material on record. We find that comparison on the basis of which the AO computed the difference in number of fruit bearing tree as per Khatoni and per the assessee statement. However the Ld. AR brought to our notice that amended khatoni was furnished before the authorities as well as before us which is available at page 14 of Paper Book as per which there is no difference. The earlier khatoni is available at page 13 on the basis of which the AO calculated the difference in fruit trees. We have examined both the khatoni and find that in the corrected khatoni and as per assessee statement there is no difference in the fruit tree. Consequently we set aside the order of Ld. CIT(A) on this issue and direct the AO to delete the addition.

3 I.T.A. No.2606/Kol/2025 Assessment Year: 2020-21 Satvik Farms 6 . In the result, the appeal of the assessee is allowed.

Order is pronounced in the open court on 1st September, 2026

Sd/- Sd/-

(Rajesh Kumar/राजेश कुमार) Accountant Member/लेखा सद�य Dated: 1st September, 2026 SM, Sr. PS

Copy of the order forwarded to: 1. Appellant- Satvik Farms, Room no. 36, 11th Floor, 23A, Netaji Subhash Road, Kolkata-700001 2. Respondent – ITO, Ward-36(1), Kolkata 3. Ld. CIT(A)- NFAC, Delhi 4. Ld. Pr. CIT- , Kolkata 5. DR, Kolkata Benches, Kolkata

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