KARUVOTH PARIYAYI,KOZHIKODE vs. ITO, WARD-1(3), KOZHIKODE

ITA 603/COCH/2025Status: DisposedITAT Cochin30 October 2025AY 2017-18Bench: SHRI INTURI RAMA RAO (Accountant Member)1 pages

AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that while the assessee failed to provide evidence for agricultural income, the AO should have estimated it based on local inquiries rather than totally disbelieving it. Regarding cash deposits, the AO and CIT(A) should have provided an opportunity for the assessee to submit evidence.

What were the facts?

The assessee's return of income for AY 2017-18 was assessed at Rs. 47,10,240/-, which included additions of Rs. 10,00,000/- for disbelieved agricultural income and Rs. 22,00,000/- for cash deposits in specified bank notes during demonetisation. The assessee claimed the cash deposits were from an earlier cash balance, but failed to provide sufficient explanation.

What were the issues?

Whether the AO was justified in disbelieving the entire agricultural income and adding the cash deposits without providing sufficient opportunity for the assessee to provide evidence.

Which sections of the Income-tax Act were involved?

Section 143(3)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, COCHIN BENCH

Before: SHRI INTURI RAMA RAO, AM

For Appellant: Shri Raghunathan, Advocate

For Respondent: Smt. Leena Lal, Sr. D.R

Hearing: 27.10.2025Pronounced: 30.10.2025

This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi [CIT(A)] dated 23.07.2025 for Assessment Year (AY) 2017-18. 2. Brief facts of the case are that the appellant is an individual. The return of income for AY 2017-18 was filed on 02.03.2018 declaring total income of Rs. 12,85,160/-. Against the said return of income, the assessment was completed by the ITO, Ward-1(3), Kozhikode (hereinafter called "the AO") vide order dated 18.11.2019 passed u/s. 143(3) of the Income Tax Act, 1961 (the Act) at a total income of Rs. 47,10,240/-. While doing so, the AO made

2 Karuvoth Pariyai addition of Rs. 10,00,000/- disbelieving the agricultural income claimed to be exempt and also made addition o

The order continues below.

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