SAULAT ALI KHAN,NOIDA, UP vs. INCOME TAX OFFICER, WARD - 71(3), DELHI

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ITA 3860/DEL/2026Status: DisposedITAT Delhi15 July 2026AY 2020-213 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal found it appropriate to make a lump sum addition of Rs. 5 lakhs to the assessee's income. This decision was made in the interest of justice and not to be treated as a precedent.

What were the facts?

The assessee claimed agricultural income of Rs. 31.50 lakhs, but the lower authorities restricted it to Rs. 4,82,500/-. The assessee's bank account showed credits of Rs. 17.31 lakhs from nurseries.

What were the issues?

The primary issue was the extent of agricultural income that could be claimed by the assessee and the validity of the addition made by the revenue authorities.

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 “SMC” NEW DELHI

Before: SH. SATBEER SINGH GODARA

Hearing: 02.06.2026Pronounced: 02.06.2026

This assessee’s appeal for Assessment Year: 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and Order No. ITBA/NFAC/S/250/2025- 26/1085986700(1), dated 13.02.2026 involving proceedings under section 143(3) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as the ‘the Act’).

Heard both the parties. Case file perused.

2 I.T.A. No. 3860/Del/2026 2. It emerges at the outset during the course of hearing that the assessee/appellant is aggrieved against the lower authorities’ assessment and lower appellate findings restricting his claim of having derived agricultural income amounting to Rs. 31.50 lakhs to Rs. 4,82,500/- only. This is what forms the sole substantive issue for the tribunal’s apt adjudication in the instant appeal.

3.

I have given my thoughtful consideration to the assesse’s and the Revenue’s respective submissions. Learned counsel more particularly argues that once the assessee had declared an agricultural income of Rs. 4.82 lakhs in the preceding assessment year, both the lower authorities couldn’t have adapted the very figure in the impugned assessment year. When the assessee’s bank account had rather reflected credits of Rs. 17.31 lakhs coming from four nurseries as well as which could not be prima facie treated as unexplained. Be that as it may, it is deemed appropriate in the larger interest of justice that a lump sum addition of Rs. 5 lakhs only in the assessees would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs. 26,67,500/- in other words. Necessary computation shall follow as per law.

3 I.T.A. No. 3860/Del/2026 4. This assessee’s appeal is partly allowed.

Order pronounced in the open court as on 02.06.2026

Sd/- (SATBEER SINGH GODARA) JUDICIAL MEMBER Dated 15th July, 2026 *GP/Sr.PS* Copy of the order forwarded to: (1) Appellant: (2) Respondent: (3) CIT (4) CIT (Appeals) (5) DR, I.T.A.T. Assistant Registrar

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