What did the Tribunal hold?

The Tribunal found that the CIT(A) dismissed the appeal without properly considering the assessee's explanation regarding agricultural income and cash deposits. The case was set aside to the CIT(A) for fresh adjudication.

The assessee declared NIL income and agricultural income of Rs. 5,79,211/-. The AO made additions of Rs. 10,45,200/- for cash deposits and disallowed agricultural income, treating it as income from other sources.

What were the issues?

Whether the CIT(A) erred in confirming additions without proper consideration of the assessee's explanation regarding cash deposits and agricultural income.

Ram Lal Dhingra, Kichha, Udham… vs ITO | ITAT Dehradun 2026

Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI

For Respondent: Shri Deepak Chaudhary, JCIT-VC

Hearing: 17.08.2026Pronounced: 17.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI BEFORE SH. SATBEER SINGH GODARA, JUDICIAL MEMBER AND SH. NAVEEN CHANDRA, ACCOUNTANT MEMBER ITA No. 149/DDN/2026 (Assessment Year : 2017-18) Ram Lal Dhingra Vs. ITO-Ward-2(1)(5) Kichha, Udham Singh Nagar, Rudrapur Uttrakhand – 263 153 Uttarakhand – 263 153 PAN No. BOBPD 3986 C (APPELLANT) (RESPONDENT) Assessee by –None- Revenue by Shri Deepak Chaudhary, JCIT-VC Date of hearing: 17.08.2026 Date of Pronouncement: 17.08.2026 ORDER PER NAVEEN CHANDRA, ACCOUNTANT MEMBER : This captioned appeal has been filed by the assessee against the order of the learned Commissioner of Income Tax, Appeals, Addl/JCIT(A)-5, Mumbai [‘CIT(A)’ in short] dated 05.03.2026 arising from the assessment order under section 143(3) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’) dated 27.12.2019 passed by the ITO, Ward 2(1)(5), Rudra Pur (hereinafter referred as ‘the AO’) for the Assessment Year 2017-18.

ITA No. 149/DDN/2026 [A.Y 2017-18] Ram Lal Dhingra vs. ITO 2. None appeared on behalf of the assessee. We heard the ld. DR at length who assisted us with the facts of the case. Case records carefully perused and considered.

The grounds of appeal raised by the assessee are as under : “1. The Ld. Commissioner of Income Tax (Appeals) has erred in law and on facts in confirming addition of Rs.10,45,000/- on account of cash deposits, with total disregard to the facts and circumstances of the case. 2. The Ld. Commissioner of Income Tax (Appeals) has further erred in confirming the addition of Rs.5,79,211/- being agricultural income of the assessee treated as income from other sources. 3. The assessee reserves its right to add, amend, alter or delete any ground of appeal at the time of hearing.”

Brief facts of the case are that the assessee had filed a return of income for A.Y. 2017-18 on 30.03.2019 declaring total income of Rs.NIL and agricultural income of Rs.5,79,211/-. The case of the assessee was selected for limited scrutiny through CASS on the basis of large agricultural income and cash deposits during demonetization period. The assessment was completed under section 143(3) of the Act by making an addition of Rs.10,45,200/- being cash deposit in bank during demonetization period and disallowed the agricultural income of Rs.5,79,211/- and was added under income from other sources as the same was not supported with substantial evidences.

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ITA No. 149/DDN/2026 [A.Y 2017-18] Ram Lal Dhingra vs. ITO 5. Being aggrieved with the assessment order, assessee filed appeal before the ld. CIT(A), the ld. CIT(A) has dismissed the appeal. 6. The assessee is aggrieved and has come in appeal before us. The ld DR relied on the AO/CIT(A). 7. We have heard the rival submissions and have perused the relevant material on record. In the instant case, we find that the CIT(A) has dismissed the appeal in absence of explanation of the assessee. We find that the assessee had explained that the assessee had adequate parcel of land and the cash deposits are out of receipts from agricultural activities. The CIT(A), we find, has rejected the assessee’s explanation without explaining the reasons for doing so. In view of the above factual matrix, and in the interest of natural justice, we are of the considered view that the issues be set aside to the file of the CIT(A) for adjudication afresh. The CIT(A) is directed to accord three effective opportunities to the assessee to present his case. Likewise, the assessee is directed to avail the opportunities and furnish evidence/materials as required by the CIT(A). The grounds are disposed off in aforesaid terms. 8. In the result, appeal of the assessee in ITA No. 149/DDN/2026 is allowed for statistical purposes.

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ITA No. 149/DDN/2026 [A.Y 2017-18] Ram Lal Dhingra vs. ITO Order pronounced in the open court on 17.08.2026 Sd/- Sd/- (SATBEER SINGH GODARA) (NAVEEN CHANDRA) JUDICIAL MEMBER ACCOUNTANT MEMBER Date:- 24.08.2026 Priti Yadav, Sr. Ps* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT NEW DELHI

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RAM LAL DHINGRA,KICHHA, UDHAM SINGH NAGAR vs. ITO-WARD-2(1)(5) RUDRAPUR, RUDRAPUR

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