SHRISHIL DHULAPPA HONAVAD ,BIJAPUR vs. INCOME TAX OFFICER, WARD-1 & TPS, BIJAPUR

ITA 2347/BANG/2025Status: DisposedITAT Bangalore17 March 2026AY 2021-22Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the addition made by the AO and sustained by the CIT(A) under Section 69A was not justified. The Tribunal noted that the ownership of the land and the fact of agricultural activity were not disputed, and the AO did not provide material to show income from sources other than agriculture. The absence of bills alone cannot be a sole ground for treating receipts as unexplained income, especially given the nature of rural agricultural transactions.

What were the facts?

The assessee, an individual agriculturist, declared agricultural income. The AO disallowed Rs. 7,00,761/-, treating it as unexplained money under Section 69A, due to the lack of bills and vouchers for sales made in the local market. The assessee's explanation was that agricultural transactions in rural areas often lack formal documentation and relied on Tipperary books and sales to registered dealers.

What were the issues?

Whether the disallowance of agricultural income of Rs. 7,00,761/- and treating it as unexplained under Section 69A is justified in the absence of formal bills for local sales, considering the assessee is an agriculturist.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE,Section 44AA,Section 250

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Income Tax Appellate Tribunal, ‘SMC’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Shri Siddesh, CA
For Respondent: Shri Ganesh R Ghale, Advocate – Standing
Hearing: 12.03.2026Pronounced: 17.03.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

The present appeal has been instituted by the assessee against the order of the Ld. CIT(A) passed u/s 250 of the Act dated 22.08.2025. 2. The effective issue raised by the assessee is that the learned CIT(A) the erred in confirming the disallowances of agricultural income of Rs. 7,00,761/- and treating the same as unexplained under section 69A of the Act.

3.

The facts in brief are that the assessee, an individual, filed return of income for the year under consideration declaring total income of Rs. 1,15,943/- and agricultural income of Rs. 29,24,800/- only. The AO observed that the assessee had declared agricultural income fro

The order continues below.

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