MOHAN YADAV, DURG,DURG vs. INCOME TAX OFFICER, BHILAI, BHILAI

ITA 686/RPR/2026Status: HeardITAT Raipur12 October 2026AY 2013-148 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the order of the CIT(Appeals)/NFAC and remanded the matter back to its file. The Tribunal granted a final opportunity to the assessee to represent his case on merits by filing relevant documents to establish the nature and source of the cash deposits. The CIT(Appeals)/NFAC was directed to comply with the principles of natural justice. The Tribunal noted that while the assessee had submitted proof of land holding and cultivation expenditure, and affidavits of brokers, no documentary evidence linking the sale proceeds to the cash deposits for the assessment year under appeal was furnished. The CIT(Appeals) had correctly observed that a satisfactory nexus between agricultural activity and the specific deposits was missing. However, considering the assessee's submission that he would provide all documents and in the interest of substantive justice, the matter was remanded. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Mohan Yadav, for Assessment Year 2013-14, did not file a return of income. Based on information of a Rs. 25,01,360 deposit in a bank account during FY 2012-13, the Assessing Officer (AO) initiated reassessment proceedings under Section 148. The assessee eventually filed a return declaring Rs. 10,596 income and Rs. 12,74,840 agricultural income. Despite being asked for evidence of sale proceeds of agricultural produce, including mandi receipts and transport receipts, the assessee failed to provide any documentary proof. The AO added Rs. 7,92,326, representing the peak credit in the bank account, to the assessee's income under Section 69A, holding that the agricultural income claim was unsubstantiated. The CIT(Appeals)/NFAC upheld this addition.

What were the issues?

1. Whether the addition of Rs. 7,92,326 under Section 69A of the Income Tax Act, 1961, as unexplained cash credits, is justified, considering the assessee's claim of agricultural income and the lack of documentary evidence of sale proceeds? (Question of law and fact, turning on Section 69A). Assessee's Contention: The assessee argued that he is an agriculturist and had submitted all necessary documents to the revenue authorities. He also pointed to a comparable pattern of cash deposits and agricultural income accepted in his scrutiny assessment for Assessment Year 2011-12. The assessee's counsel stated that he would provide all documents justifying the cash deposits. Revenue's Contention: The revenue, through the Assessing Officer and the CIT(Appeals)/NFAC, argued that while the assessee proved capacity to cultivate land, he failed to establish a satisfactory nexus between agricultural activity and the specific bank deposits. Crucially, no documentary evidence of sale realization, such as mandi receipts or transport receipts, was furnished, rendering the claim unsubstantiated. The CIT(Appeals) distinguished relied-upon case laws based on the lack of corroborative evidence.

Which sections of the Income-tax Act were involved?

Section 139(1),Section 148,Section 142(1),Section 143(2),Section 143(3),Section 147,Section 144B,Section 69A,Section 151,Section 274,Section 271(1)(c)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “SMC”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY

For Appellant: Shri Moolchand Jain, Advocate
For Respondent: Shri Piyush Tripathi, Sr. DR
Hearing: 12.10.2026Pronounced: 12.10.2026

PER PARTHA SARATHI CHAUDHURY, JM

The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 23.07.2026 for the assessment year 2013-14 as per the grounds of appeal on record.

2.

Brief facts in this case are as follows: “1.1 The assessee MOHAN YADAV having PAN AETPY9420R is an individual assessed to income tax for Assessment Year 2013-14. No return of income under section 139(1) of the Act was furnished for the year. On the basis of informatio

The order continues below.

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