GOMA RAM CHOUDHARY,PALI vs. ITO, WARD-1, PALI

ITA 270/JODH/2025Status: DisposedITAT Jodhpur13 August 2026AY 2013-145 pages
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What did the Tribunal hold?

The Tribunal found that while the assessee owned agricultural land, the accumulation of income over 13 years and its availability in cash were not sufficiently substantiated. However, rejecting the entire explanation was also deemed inappropriate.

What were the facts?

The assessee deposited ₹12,37,225/- in cash with Nagar Parishad for land conversion. The Assessing Officer treated this as unexplained income, which was upheld by the CIT(A). The assessee claimed the source was accumulated agricultural and interest income over several years.

What were the issues?

Whether the cash deposit made by the assessee for land conversion was sufficiently explained by accumulated agricultural and interest income, and if not, to what extent the addition should be sustained.

Which sections of the Income-tax Act were involved?

Section 147,Section 144

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JODHPUR BENCH, JODHPUR

For Appellant: CA (Physical)
For Respondent: DR (Physical)

PER BENCH: The aforesaid appeal has been filed by the assessee against the impugned order dated 05.02.2025 passed by the Ld. CIT(A), NFAC, arising out of the assessment order passed under section 147 read with section 144 of the Income- tax Act, 1961. The principal grievance before us relates to the addition of ₹12,37,225/- made by the Assessing Officer by treating the amount deposited by the assessee with Nagar Parishad, Pali, as unexplained.

2.

The relevant facts, in brief, are that the assessee had deposited a sum of ₹12,37,225/- in cash with Nagar Parishad, Pali on 18.03.2013 towards charges for conversion/development of agricultural land for residential purposes. During the 2 Asst. Year: 2013-14 course of assessment proceedings, th

The order continues below.

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