SMT. KAUSHALYA DEVI CHAYAL,BIKANER. vs. DCIT/ACIT, CENTRAL CIRCLE, BIKANER
What did the Tribunal hold?
The Tribunal held that the AO's estimation of reduced yield and increased expenditure lacked material evidence. The agricultural activity itself was not doubted, and the additions were based on ad-hoc estimations.
What were the facts?
The assessee declared agricultural income from date palm cultivation. The Assessing Officer (AO) made additions by treating a portion of receipts as non-agricultural and estimating agricultural expenditure at 40% of gross receipts.
What were the issues?
Whether the AO can make additions to agricultural income and expenditure based on estimations without contradicting actual disclosed figures and operations.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, JODHPUR BENCH, JODHPUR
PER BENCH: The aforesaid appeal has been filed by the assessee against the impugned order dated 09.12.2024 passed by the Ld. CIT(A)/NFAC, arising out of the assessment order passed under section 143(3) read with section 144B of the Income-tax Act, 1961, for the Assessment Year 2018-19. The assessee is mainly aggrieved by the addition of ₹2,30,714/- by treating part of the agricultural receipts as non-agricultural income and further addition of ₹6,11,556/- on 2 Asst. Year: 2018-19 account of alleged understatement of agricultural expenditure by estimating the same at 40% of the gross agricultural receipts.
The relevant facts, in brief, are that the assessee had declared agricultural income of ₹63,1
The order continues below.
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