JAY SHANKER PRASAD,GODDA vs. ITO WARD 5(1)(3), NOIDA, NOIDA, UTTAR PRADESH

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ITA 1894/DEL/2026Status: DisposedITAT Delhi27 July 2026AY 2020-213 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found that accumulated past savings of the assessee's late father and crop produce could not be entirely ruled out. Therefore, a lumpsum addition of Rs. 10 lakhs was deemed just and proper, with the relief granted to the assessee being Rs. 36,42,765/-.

What were the facts?

The assessee claimed agricultural income of Rs. 58,42,765/-. The Assessing Officer disallowed the entire claim, and the CIT(A) restricted it to Rs. 12,00,000/-. The assessee claimed the land was 23 acres, while the AO noted it as 12.98 acres.

What were the issues?

The primary issue was the genuineness and quantum of the assessee's claimed agricultural income and the ownership of the agricultural land.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B

AI-generated summary — verify with the full judgment below

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

Before: SHRI SATBEER SINGH GODARA & SMT RENU JAUHRI

Hearing: 22.07.2026Pronounced: 22.07.2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SMT RENU JAUHRI, ACCOUNTANT MEMBER ITA No. 1894/Del/2026 Assessment Year: 2020-21 Jay Shanker Prasad Vs Income Tax Officer House No. 42, Punsia, Ward 5(1)(3), Godda, Income Tax Department, Godda College, B.O. Godda,-814133 Sector-20, Gautam Budh Jharkhand Nagar, Noida- 201301 Uttar Pradesh (APPELLANT) (RESPONDENT) PAN No. AMJPP3088Q

Assessee by: Sh. Aditya Rathor, Adv. Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 22.07.2026 Date of Pronouncement: 22.07.2026

ORDER This assessee’s appeal for Assessment Year 2020-21 arises against the Commissioner of Income Tax(Appeals)/National Faceless Appeal Centre (for short, “the CIT(A)/NFAC”), Delhi’s DIN & Order no. ITBA/NFAC/S/250/2025-26/1086044613(1) dated 16.02.2026, involving proceedings u/s 143(3)r.w.s. 144B of the Income Tax Act, 1961; hereinafter referred to as, “the Act”. Heard both the parties. Case file perused.

2 2. It transpires at the outset during the course of hearing that the assessee/appellant is aggrieved against both the learned lower authorities’ respective findings declining his agricultural income claim of Rs. 58,42,765/- in entirety in assessment order dated 22.09.2022 partly restricted to Rs. 46,42,765/- in the lower appellate discussion; forming the sole subject matter of the tribunal’s apt adjudication herein.

3.

That being the case, we sought to ascertain assessee’s alleged thereof i.e. ownership of his agricultural land. We are informed that he happens to be the son of Shri Rabi Shankar Prasad who admittedly left for his heavenly abode on 21.03.2021. Coming to the ownership of the land in issue, the Assessing Officer’s assessment discussion reveals at page Nos. 2 to 3 that the asessee had claimed the land in question as admeasuring 12.98 acres whereas his grounds of appeal raised herein states the same to be 23 acres. Thers is further no dispute that the learned CIT(A) has granted relief to him to the extent of Rs. 12 Lakhs i.e. broadly @ Rs. 1 lakh agricultural income per acre only.

4.

We have given our thoughtful consideration to the assessee’s and the Revenue’s respective pleadings against and in support of the impugned addition. We are of the considered view that be it 12.98 acres or 23 acres; as the case may be, the

3 fact remains that possibility of accumulated past savings of the assessee late father as well as the relevant crop produce raised thereupon involving the highly unorganized sector; as the case maybe, could not be altogether ruled out in the peculiar facts involved herein. We accordingly deem it appropriate to that a lumpsump addition of Rs. 10lakhs only in the given facts in the assessee’s hands in such a backdrop would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs. 36,42,765/- in other words. Necessary computation shall follow as per law. No other ground or argument has been pressed.

5.

This assessee’s appeal is partly allowed in above terms.

Order pronounced in the open court on 22.07.2026 .

Sd/- Sd/- (RENU JAUHRI) (SATBEER SINGH GODARA) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 27.07.2026 *Pooja Mittal, Sr. PS* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR

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