ALEYKUTTY GEORGE,IDUKKI vs. ITO, WARD 1 AND TPS, THODUPUZHA

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ITA 468/COCH/2025Status: DisposedITAT Cochin31 July 2025AY 2020-21Bench: SHRI INTURI RAMA RAO (Accountant Member)3 pages
AI SummaryAllowed (for statistical purposes)

What did the Tribunal hold?

The Tribunal determined that the core issue was the estimation of agricultural income. It remanded the case back to the Assessing Officer, directing the AO to re-estimate the agricultural income based on comparable cases in the relevant assessment year and after providing the assessee a reasonable opportunity of being heard.

What were the facts?

The assessee, an individual cultivating cardamom on 2.75 acres, filed a return declaring agricultural income, claiming an exemption. The Assessing Officer (AO) accepted only Rs. 5,00,000 as agricultural income and added the balance Rs. 27,33,394 as unexplained money, which was subsequently confirmed by the CIT(A).

What were the issues?

The key legal issue was the proper estimation of agricultural income from cardamom cultivation and the validity of the Assessing Officer's addition of unexplained money.

Which sections of the Income-tax Act were involved?

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, COCHIN BENCH

Before: SHRI INTURI RAMA RAO, AM

For Appellant: Ms. Binisha Baby, Advocate
For Respondent: Smt. Leena Lal, Sr. DR
Hearing: 22.07.2025Pronounced: 31.07.2025

This appeal filed by the assessee is directed against the order of the National Faceless Appeal Centre, Delhi [CIT(A)] dated 16.05.2025 for Assessment Year (AY) 2020-21.

2.

Brief facts of the case are that assessee is an individual, having agricultural land of 2.75 Acres, cultivating with cardamom. Return of income for the A.Y. 2020-21 was filed on 10/01/2021 declaring total income of Rs. 6,260/- after claiming exemption of net Alekutty George agricultural income of Rs. 38,05,996/-. The assessee shown agricultural receipt of Rs. 64,06,826/- from cultivation of cardamom against which expenses of Rs. 26,00,830/- were claimed. The balance income was shown as agricultural income 38,05,996/-. Against the said return of income, the AO made addition accepting the agricultural income to the extent of Rs. 5,00,000/- and brought to tax the balance amount of Rs. 27,33,394/- as unexplained money of the assessee.

3.

Being aggrieved, an appeal was filed before the CIT(A), who vide the impugned confirmed the action of the AO.

4.

Being aggrieved, the assessee is in appeal before this Tribunal in the present appeal.

5.

I have heard rival submissions and perused the material on record.

6.

The issue in the present appeals relates to the estimation of agricultural income on 2.75 Acres of land, on which cardamom stated to have been cultivated. I am of the considered opinion that the matter requires remand to the file of AO for estimation of agricultural income based on the comparable cases in the relevant assessment year. Accordingly, the matter is restored to the file of AO directing to redo the assessment after affording a reasonable opportunity of being heard to the assessee.

Order pronounced in the open court on 31st July, 2025. 8.

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