ROHAN SINGH,BHARATPUR vs. INCOME TAX OFFICER, WARD-1, BHARATPUR, BHARATPUR

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “SMC” BENCH, JAIPUR BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER ITA No. 1876/JPR/2025 (Assessment Year:2020-21)

Rohan Singh Vs. ITO S/o Shri Moti Singh, Vill. Ward 1 Pipla, Distt Bharatpur Bharatpur �थायीलेखासं./जीआइआरसं./PAN/GIR No:MHPPS 6657 F Appellant .. Respondent

Appellant by : Sh. Rajendra Agarwal, CA Respondent by : Mrs. Aarti Rawat, JCIT

Date of Hearing 15.07.2026 Date of Pronouncement 29.07.2026 O R D E R The present appeal has been filed by the assessee against the order passed by the National Faceless Appeal Centre (NFAC), Delhi(hereinafter referred to as “Ld. CIT(A)”), dated 26.11.2025 under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”). 2. The assessee has raised the following grounds of appeal:- 1. The Ld. CIT(A) erred in dismissing the appeal and confirming the addition of Rs.21,81,300/- towards cash deposit in the bank account.

P a g e | 2 ITA No. 1876/JPR/2025 Rohan Singh 3. The solitary issue in the present appeal pertains to cash deposited in the Bank Account of the assessee amounting to Rs.21,81,300/-, the source of which remained unexplained and accordingly, was added to the income of the assessee as unexplained money. 4. I have gone through the orders of Authorities below. The facts relating to cash deposit of Rs.21,81,300/- are that, they were noted to be deposited in the Bank account of the assessee with Baroda Rajasthan Kshetriya Gramin Bank, during the impugned assessment year. The assessee had filed return of income declaring exempt agricultural income of Rs.10,40,300/-, and total taxable income of Rs.1240/-. The said return had been filed in response to notice issued u/s 148 of the Act. The assessee’s explanation for the cash deposit in the bank account of the assessee was that, being a farmer owning agricultural land he had a bank account which was a Kisan Credit Card Account with a limit of Rs.9,84,000/- and the deposits of cash in said bank account were from the sale proceeds of his crop. The AO noted deposits of Rs.21,81,300/- and cash withdrawals of Rs.24,21,000/-. The assessee stated the deposits to be of agricultural sale proceeds and withdrawals to be for agricultural purposes. The assessee also pointed out some insurance compensation receipt and inter-account transfers from his savings account credited to the account..To support his contention the assessee submitted Bank statements, jamabandi, KCC Sanction letter, and Girdawari reports (crop records). 5. The AO and Ld. CIT(A) acknowledged the land ownership and the Girdawari reports, but rejected the assessee’s explanation for the

P a g e | 3 ITA No. 1876/JPR/2025 Rohan Singh reason that the assessee had not evidenced sale of crops by bills and the vouchers, i.e. direct financial evidence. The Ld. CIT(A) at para 4.4 of his order has admitted to the fact that the jamabandi and Girdawari submitted by the assessee successfully establish that the assessee is a farmer and crops were cultivated, but they do not prove the price at which the produce was sold, nor the date of sale. 6. In short, the insistence of the Revenue Authorities was that, the assessee produce sales bill to evidence the quantum of sales made by it, so as to justify the cash deposit in his Bank account as emanating from the sale of crops. 7. During the course of hearing before me, ld. Counsel for the assessee contended that the crops are cultivated and grown in two or three seasons and the amount of Rs.21,81,300/- accordingly can be spread to three seasons ,attributing the crops grown and sales to be to the extent of Rs.6 to 7 lakhs approx, in each season, which clearly shows that the assessee was a small farmer . And considering the fact that he was not even literate, it was therefore practically impossible and improbable to conduct operations in a systematic manner through generating sales bills or receipts. He contended that the fact that the assessee deposited the cash in his bank account from the sale of crops is evident from the bank statement itself wherein the majority of the deposits are made in particular months. He drew my attention to the copy of the bank statement placed before me at paperbook page No.1 pointing out therefrom that the cash was deposited during the impugned year of Rs.6,97,000/- on 27.05.2019 of Rs.6,70,000/- on 30.09.2019

P a g e | 4 ITA No. 1876/JPR/2025 Rohan Singh and of Rs.1,61,000/- and Rs.8,14,000/- on 19.11.2019 and against with the aforesaid credits, he pointed out that there was withdrawal of cash alsoof corresponding with the deposits for meeting the expenditure of agricultural activities. He contended that these deposits of cash reflected the receipts from sale of crops cultivated in the month of May, September and November by the assessee, and sufficiently proved that the cash was generated from his agricultural activities alone. 8. Having gone through the orders of the Authorities below, and having heard the ld. Counsel for the assessee as also, the ld. DR, I hold that the Authorities below have grossly erred and have been unjust in treating the cash deposited in the bank account of the assessee as unexplained. 9. As noted above, they have accepted the fact, that the assessee was the owner of agricultural land indulging in agricultural activities, and the only reason for rejecting the assessee’s explanation of the cash deposit emanating from sale of agricultural produce is that the assessee had not adduced direct evidence of sale of crops. The ld. Counsel for the assessee has fairly demonstrated before me, that the cash deposited in the bank account of the assessee was in three trenches accompanied with subsequent and substantial withdrawal, which I hold, fairly demonstrates that the cash emanated from the harvesting of crops grown by it in particular seasons. 10. There being no doubt of the assessee indulging in agricultural activities and growing crops therein and the bank account sufficiently reflecting the deposit of cash in particular harvesting season, it

P a g e | 5 ITA No. 1876/JPR/2025 Rohan Singh sufficiently corroborates and substantiates assessee’s explanation of the cash deposit emanating from the sale of agricultural produce alone. The Department expecting the assessee agriculturalist, operating at such a small level, to be in a possession of documents evidencing sale of agricultural crop, is asking for too much. Moreover the department has not found the cash deposit to be emanating from some other source. 11. The facts of the case sufficiently substantiating assessee’s explanation of the cash deposit in the bank account of the assessee emanating from sale of agricultural produce, I hold the entire cash deposit in the bank account of the assessee to the tune of Rs.21,81,300/- to be duly explained, and I delete the addition made to the income of the assessee of Rs.21,81,300/-. 12. In effect, the appeal of the assessee is allowed. Order pronounced in the Open Court on 29.07.2026

Sd/- (Annapurna Gupta) ACCOUNTANT MEMBER Dated 29.07.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT

P a g e | 6 ITA No. 1876/JPR/2025 Rohan Singh By Order, Asst. Registrar ITAT, Jaipur