RISHI RAJ,GADDI CHOOPAD, PAHALADPUR vs. INCOME TAX OFFICER, SONIPAT

Asstt. Year : 2012-13 Rishi Raj, Vs Income Tax Officer, Kharkhoda, Ward-5, Sonipat, Haryana-131001 Sonipat, Haryana-131001 (APPELLANT) (RESPONDENT) PAN No. AWOPR6954Q Assessee by: None Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 30.10.2025 Date of Pronouncement: 30.10.2025 ORDER

This assessee’s appeal for Assessment Year 2012-13, arises against the Addl./JCIT(A)-3, Mumbai’s DIN & order No. ITBA/APL/S/250/2025-26/1079300403(1) dated 05.08.2025, in proceedings u/s 143(3) r.w.s. 147 of the Income Tax Act, 1961 (in short “the Act”).

Rishi Raj 4. I have given my thoughtful consideration to the assessee’s pleadings all along and the Revenue’s foregoing vehement contentions. I find no reason to sustain the impugned addition in entirety. This is for the precise reason that the assessee admittedly happens to be an agriculturist being owner in possession of lands admeasuring at least 4.5 acres which is not in dispute. The fact further remains that he has also claimed 4 acres in the capacity of a lessee which has not been specifiedly rebutted in both the lower proceedings. That being the case, the necessary inference which would arise in such an instance is that the impugned cash deposits prima facie represent the assessee’s agricultural income derived from the foregoing agricultural lands. It is thus deemed appropriate in the larger interest of justice that a lump sum addition of Rs.1,00,000/- only would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs.10,00,000/- in other words. Necessary computation shall follow.