PERIANAYAGAM JEYASURESH JAYARAJ,MADURAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, NON-CORPORATE CIRCLE -2, MADURAI, MADURAI

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ITA 4147/CHNY/2025Status: DisposedITAT Chennai11 August 2026AY 2018-195 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the assessee should be granted another opportunity to substantiate the claim of agricultural income by producing relevant documentary evidence before the first appellate authority. The matter was restored to the file of the CIT(A) for fresh adjudication.

What were the facts?

The assessee claimed agricultural income of Rs. 23,00,000/- in his return. The Assessing Officer treated this as income from undisclosed sources under Section 68. The CIT(A) confirmed this addition as the assessee failed to provide supporting evidence for the agricultural income.

What were the issues?

Whether the assessee's claim of agricultural income was rightly rejected due to lack of documentary evidence, and if a further opportunity should be granted to substantiate the claim.

Which sections of the Income-tax Act were involved?

Section 68,Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRIS.R.RAGHUNATHA

Hearing: 09.07.2026

आयकरअपील�यअ�धकरण ’बी’ �यायपीठ,चे�नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH: CHENNAI �ी मनुकुमारिग�र, �ाियक सद� एवं �ी एस. आर. रघुनाथा लेखासद� BEFORE SHRI MANU KUMAR GIRI, JUDICIAL MEMBER AND SHRIS.R.RAGHUNATHA, ACCOUNTANT MEMBER

आयकर अपील सं./ITA No. 4147/Chny/2025 �नधा�रण वष�/Assessment Year: 2018-19 Perianayagam Jeyasuresh v. The Assistant Commissioner Jayaraj, of Income Tax (ACIT) No. 1, Jayaraj Nagar, Opposite Non-Corporate Circle-2, Fathima College, Madurai-625002 Madurai-625018 [PAN: AEPPJ 4375 Q] (Appellant) (Respondent)

अपीलाथ� क� ओर से/ Appellant by : Ms. Joshitha Joshi, CA !यथ� क� ओर से /Respondent by : Ms. P. Sunanda, JCIT सुनवाई क� तार�ख/Date of Hearing : 09.07.2026 : 11.08.2026 घोषणा क� तार�ख /Date of Pronouncement आदेश / O R D E R PER MANU KUMAR GIRI, JM:

The captioned appeal filed by the Assessee is directed against the order of the Ld. Commissioner of Income Tax (Appeal), NFAC, Delhi[hereinafter referred to as “the Ld.CIT(A)”], dated 08.10.2025 confirming the assessment order framed u/s. 143(3) of the Income Tax Act, 1961 for Assessment Year 2018-19.

2.

The assessee filed his return of income for the Assessment Year (AY) 2018-19 declaring taxable income of Rs.2,16,37,100/- and agricultural income of Rs.23,00,000/-. The assessment was

ITA No. 4147/Chny/2025 (AY 2018-19) Perianayagam Jeyasuresh Jayaraj Vs ACIT NCC-2 :: 2 :: completed under section 143(3) of the Income-tax Act, 1961. During the course of assessment, the Assessing Officer did not accept the agricultural income of Rs.23,00,000/- claimed by the assessee and treated the same as income from undisclosed sources under section 68 of the Act.

3.

Aggrieved by the assessment order, the assessee preferred an appeal before the ld. CIT(A). During the appellate proceedings, the assessee was required to substantiate the claim of agricultural income. However, according to the ld. CIT(A), the assessee failed to furnish supporting evidence such as patta/passbook, evidence regarding sale of agricultural produce, details of agricultural expenses and other records evidencing actual agricultural operations. The ld. CIT(A), therefore, dismissed the appeal of the assessee and confirmed the addition of Rs.23,00,000/-.

Now assessee is in appeal before the Tribunal.

4.

The ld.AR for the assessee submitted that the assessee had duly disclosed agricultural income of Rs.23,00,000/- in the return of income and that the said income was claimed as agricultural income. He contended that the claim could not be rejected merely for want of certain supporting documents without properly examining the nature of the agricultural activity and the material available on record. He further submitted that the assessee should be granted a proper and effective opportunity to substantiate the agricultural income by producing the relevant documentary evidence, including records relating to agricultural land, agricultural operations, sale of agricultural produce and expenditure incurred in

ITA No. 4147/Chny/2025 (AY 2018-19) Perianayagam Jeyasuresh Jayaraj Vs ACIT NCC-2 :: 3 :: earning such income. The assessee accordingly prayed that the matter may be restored to the file of the ld.CIT(A) for fresh adjudication after providing an adequate opportunity to produce the necessary evidence and after considering the same in accordance with law.

5.

The ld. Departmental Representative (DR) Ms. P. Sunanda, JCIT supported the orders of the Assessing Officer and the ld. CIT(A). It was submitted that the assessee had claimed agricultural income of Rs.23,00,000/- but had failed to substantiate the same with cogent documentary evidence. She argued that mere ownership or possession of agricultural land does not establish that agricultural operations were actually carried out or that the claimed amount was earned from sale of agricultural produce. In the absence of evidence regarding agricultural operations, sale of produce, agricultural expenditure and other supporting records, the claim of agricultural income was rightly rejected. The ld. DR, therefore, supported the addition made by the Assessing Officer and confirmed by the ld. CIT(A).

6.

We have heard the rival submissions and perused the material available on record. The assessee has claimed agricultural income of Rs.23,00,000/- for the year under consideration. The ld. CIT(A) has confirmed the addition primarily on the ground that the assessee failed to furnish adequate documentary evidence in support of the agricultural activities and the agricultural income claimed. At the same time, it is noticed that the dispute essentially relates to the factual question as to whether the assessee had in fact carried out agricultural operations and earned agricultural income of

ITA No. 4147/Chny/2025 (AY 2018-19) Perianayagam Jeyasuresh Jayaraj Vs ACIT NCC-2 :: 4 :: Rs.23,00,000/- during the relevant previous year. Such issue requires examination of the relevant factual and documentary material, including the details of agricultural land, crops cultivated, agricultural operations carried out, sale of agricultural produce, agricultural expenditure and other supporting records. In the interest of substantial justice, we are of the considered view that the assessee should be afforded one more effective opportunity to substantiate his claim by producing the relevant evidence before the first appellate authority. The ld. CIT(A), being the first appellate authority, is competent to examine the additional material and adjudicate the factual issue after considering the explanation of the assessee as well as the stand of the Assessing Officer. Accordingly, without expressing any opinion on the merits of the claim of agricultural income, we deem it appropriate to set aside the impugned order of the ld. CIT(A) and restore the matter to his file for fresh adjudication. The ld. CIT(A) shall provide reasonable and effective opportunity of hearing to the assessee and shall consider the evidence, documents and explanations furnished by the assessee in support of the agricultural income of Rs.23,00,000/-. The assessee is also directed to fully cooperate with the proceedings and furnish all relevant documentary evidence in support of his claim. The ld. CIT(A) shall thereafter decide the issue afresh in accordance with law by passing a speaking order. Needless to say, the assessee shall not seek unnecessary adjournments and the Revenue shall also be at liberty to verify the evidence furnished by the assessee in accordance with law.

ITA No. 4147/Chny/2025 (AY 2018-19) Perianayagam Jeyasuresh Jayaraj Vs ACIT NCC-2 :: 5 :: 7. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open court on the 11th day of August, 2026 in Chennai.

Sd/- Sd/- (एस. आर. रघुनाथा) (मनु कुमार िग�र) (S.R.RAGHUNATHA) (MANU KUMAR GIRI) लेखा सद*य/ACCOUNTANT MEMBER �या�यक सद*य/JUDICIAL MEMBER चे�नई/Chennai, +दनांक/Dated: 11th August 2026. SNDP, Sr. PS आदेश क� �त,ल-प अ.े-षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

SANDE Digitally signed by SANDEEP EP KUMAR Date: 2026.08.12 KUMAR 17:40:30 +05'30'

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