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“agricultural income”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(1A) / Rule 7, 7A, 7B(1), 7B(1A), 82,868 judgments

The decision most relied on for agricultural income is CIT v. Ghanshyam (HUF) (315 ITR 1), cited in 363 judgments on BharatTax.

Leading authorities on agricultural income

CIT v. Ghanshyam (HUF)
315 ITR 1 · 2009 · Supreme Court
363
citing judgments

Interest received under Section 28 of the Land Acquisition Act, 1894, is considered part of the enhanced compensation on compulsory acquisition of land. It is taxable as 'capital gains' and not separately as 'interest income' under the head Income from Other Sources.

CIT v. Punjab State Cooperative Agricultural Development Bank Ltd.
389 ITR 68 · 2016 · High Court
192
citing judgments

Income earned by a cooperative society from investing its surplus funds in short-term deposits and securities is not attributable to its core activities and therefore not eligible for deduction under Section 80P(2)(a)(i) of the Income-tax Act.

Mavilayi Service Co-operative Bank Ltd. v. CIT
414 ITR 67 · 2019 · High Court
190
citing judgments

The Full Bench of the Kerala High Court held that a co-operative bank or society is not entitled to a deduction under Section 80P(2)(a)(i) of the Income-tax Act if it provides loans to non-members. This decision was subsequently overruled by the Supreme Court.

Smt. Harshila Chordia v. ITO
298 ITR 349 · 2008 · High Court
187
citing judgments

Cash receipts from customers against genuine delivery of goods or services cannot be added as unexplained cash credits under Section 68. The case also provides guidance on non-disallowance under Section 40A(3) for business payments made in specific contexts like agricultural markets.

Kerala State Co-operative Agricultural and Rural Development Bank Ltd. v. Assessing Officer
154 Taxmann.com 305 · 2023 · Supreme Court
136
citing judgments

Section 80P(4) is not applicable to a cooperative bank unless it is classified as a 'bank' under the provisions of the Banking Regulation Act, 1949. For cooperative banks not meeting this definition, the deduction for interest earned from investments in cooperative societies is available under Section 80P(2)(d) of the Income-tax Act.

CIT v. Raja Benoy Kumar Sahas Roy
32 ITR 466 · 1957 · Supreme Court
132
citing judgments

Income is considered agricultural income, exempt under Section 10(1), only if the land undergoes a measure of cultivation involving basic primary operations prior to germination and subsequent post-germination activities requiring human skill and labour.

Sabarkhanta Zilla Kharid Vechan Sangh Ltd. v. ClT
203 ITR 1027 · 1993 · Supreme Court
98
citing judgments

Co-operative societies or banks engaged in both agricultural and non-agricultural activities are entitled to deduction under Section 80P of the Income Tax Act, 1961, limited only to the profits derived from agricultural activities, not 100% of their gross profits.

CIT v. Usha Stud Agricultural Farms Ltd.
301 ITR 384 · 2008 · High Court
98
citing judgments

An addition cannot be made under Section 68 for cash credits if it is established that the credits do not pertain to the impugned assessment year but relate to earlier assessment years.

Judgments citing agricultural income

B Devahie, Chennai vs. ACIT, Central Cir-3(3), Chennai

In the result the ITA No

ITA 3331/CHNY/2018[2014-15]Status: DisposedITAT Chennai19 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. K.G.Raghunath, AdvocateFor Respondent: Shri. ARV Sreenivasan, C.I.T
Section 132Section 143(2)Section 144Section 153ASection 68

Rs.312.11 lakhs to the income of the assessee u/s.68 of the Act and levied the taxes accordingly. 7. The Assessing Officer also disallowed the agricultural income claimed by the assessee to the extent of Rs.224.15 Lakhs in the A.Y.2013-14 and brought to tax the same as ‘income from other sources ... Similarly, in A.Y.2014-15, the AO disallowed the agricultural income claim of the assessee to the tune of Rs.49.64 Lakhs and brought to tax the same as ‘income from other sources’. :-4-: ITA. Nos.: 3329 to 3331/Chny/2018, 67/Chny/2019 8. Aggrieved by the order of the AO, the assessee preferred appeal

B Devahie, Chennai vs. ACIT, Central Cir-3(3), Chennai

In the result the ITA No

ITA 3330/CHNY/2018[2013-14]Status: DisposedITAT Chennai19 Jan 2026AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. K.G.Raghunath, AdvocateFor Respondent: Shri. ARV Sreenivasan, C.I.T
Section 132Section 143(2)Section 144Section 153ASection 68

Rs.312.11 lakhs to the income of the assessee u/s.68 of the Act and levied the taxes accordingly. 7. The Assessing Officer also disallowed the agricultural income claimed by the assessee to the extent of Rs.224.15 Lakhs in the A.Y.2013-14 and brought to tax the same as ‘income from other sources ... Similarly, in A.Y.2014-15, the AO disallowed the agricultural income claim of the assessee to the tune of Rs.49.64 Lakhs and brought to tax the same as ‘income from other sources’. :-4-: ITA. Nos.: 3329 to 3331/Chny/2018, 67/Chny/2019 8. Aggrieved by the order of the AO, the assessee preferred appeal

B Devahie, Chennai vs. ACIT, Central Cir-3(3), Chennai

In the result the ITA No

ITA 3329/CHNY/2018[2012-13]Status: DisposedITAT Chennai19 Jan 2026AY 2012-13

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. K.G.Raghunath, AdvocateFor Respondent: Shri. ARV Sreenivasan, C.I.T
Section 132Section 143(2)Section 144Section 153ASection 68

Rs.312.11 lakhs to the income of the assessee u/s.68 of the Act and levied the taxes accordingly. 7. The Assessing Officer also disallowed the agricultural income claimed by the assessee to the extent of Rs.224.15 Lakhs in the A.Y.2013-14 and brought to tax the same as ‘income from other sources ... Similarly, in A.Y.2014-15, the AO disallowed the agricultural income claim of the assessee to the tune of Rs.49.64 Lakhs and brought to tax the same as ‘income from other sources’. :-4-: ITA. Nos.: 3329 to 3331/Chny/2018, 67/Chny/2019 8. Aggrieved by the order of the AO, the assessee preferred appeal

Income Tax Officer, Ward-41(3)(1), Mumbai vs. Dahyalal Gagjibhai Jiwani, Surat

ITA 7004/MUM/2025[2022-23]Status: DisposedITAT Mumbai19 Jan 2026AY 2022-23

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Rahul SardaFor Respondent: Shri Annavaran Kosuri
Section 143(3)Section 144BSection 68

increase during the F.Y. 2021-22 but it is increase during the last many years from my difference sources of income capital gain and agriculture income. Out of this Rs..10,63,03,636/- I have paid capital gain tax on Rs.4,03,71,968/- from Long Term Capital Gain ... income in the nature of: ○ Remuneration and share of profits from the partnership firm M/s. Srusti Diam, Interest income from bank and fixed deposits, ○ Agricultural income. 5.6 I find that the AO has AO wrongly compared the total capital in the personal balance sheet (Rs.27,05,32,933.30) with

Kanhaiya Lal Panchal, Ratlam vs. Bpl-W-(91)(95), Ratlam

In the result, the appeal of the assessee is allowed

ITA 702/IND/2025[2024-25]Status: DisposedITAT Indore16 Jan 2026AY 2024-25

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiassessment Year:2024-25 Kanhaiya Lal Panchal, Bpl-W-(91)(95) 1, Jadwasa Kala, बनाम/ Ratlam Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Aqrpp0055D Assessee By Shri Kaide Kangsawala, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 06.01.2026 Date Of Pronouncement 16.01.2026

Section 111ASection 112Section 112ASection 115BSection 143(1)Section 154Section 3(6)Section 81Section 87A

Panchal ITA No. 702/Ind/2025 – AY 2024-25 from salary, short-term capital gain, long-term capital gain and income from other sources alongwith agricultural income of Rs. 2,74,118/-. The assessee opted under new tax regime u/s 115BAC, computed tax liability of Rs. 22,536/- but claimed rebate

Mukesh Kumar, Yamunaanagar vs. ITO Ward 3 Yamunanagar, Yamunanagar

The appeal stand allowed for statistical purposes

ITA 1315/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh16 Jan 2026AY 2015-16

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./ Ita No.1315/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2015-16) Shri Mukesh Kumar Ito Ward 3 बनाम/ H. No. 76W No. 2, Sk Road Aaykar Bhawan, Sector 17, Vs. Radaur, Yamuna Nagar -135 133 Jagadhari, Yamuna Nagar - 135003 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Brups-0808-J (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Ajay Jain (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 13.01.2026 घोषणाकीतारीख /Date Of Pronouncement : 16.01.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2015- 16 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 02-09-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 147 R.W.S. 144B Of The Act On 28-03-2022. The Grounds Of Appeal Read As Under: 1. That The Ao Has Wrongly Invoked The Provisions Of Section 147/148 Of Income Tax Act, 1961. 2. That The Ao Has Wrongly Taxed Enhanced Compensation Amounting To Rs. 901726 On Acquisition Of Agricultural Land Which Is Exempt Under Section 10(37) Of Income Tax Act.

For Appellant: Sh. Ajay Jain (CA) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 10(37)Section 143(2)Section 144Section 147Section 56(2)(viii)Section 57Section 80C

assesses claimed deduction of LIC payment for Rs.1,46,630/- u/s 80C which was denied for want of supporting document. The assessee reflected exempt agricultural income of Rs.9,01,726/- which was considered as income from other sources. Finally, the income was determined at Rs.16 ... already offered 50% of interest on compensation to tax in the return of income and the same has been accepted by Ld. AO. The agricultural income of Rs.9,01,726/- is apparently amount of compensation and the same has been claimed to be exempt

Somnath Cold Storage, Gandhinagar vs. The ITO, Ward-1, Gandhinagar

In the result, the appeal of the assessee is allowed

ITA 771/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Adjournment Application FiledFor Respondent: Shri Abhijit, Sr. D.R
Section 143(2)Section 68Section 69

account of the partners, copy of affidavit by 7 partners, their bank statements as well as 7/12, proof of holding, land in support of agricultural income along with copy of return of income in case of 3 partners out of 10 partners for assessment year 2017-18 as well

Kanubhai Maganbhai Patel, Anand vs. ITO, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed

ITA 1404/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad16 Jan 2026AY 2012-13

Bench: Ms. Suchitra Kambleassessment Year 2012-13

For Appellant: Shri Parin Shah, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 148Section 234ASection 271(1)(c)Section 69A

income of the assessee as the assessee is continuously crediting the cash in the bank account which is the amount in return of the agricultural income derived by the assessee. The ld. A.R. pointed out page nos. 1 to 8 wherein the assessee has given details of bank account

Zeba Urfi, New Delhi vs. ITO, Ward-7(4), New Delhi

In the result, the appeal of the assessee is allowed

ITA 271/DEL/2020[2013-14]Status: DisposedITAT Delhi16 Jan 2026AY 2013-14

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] Ms. Zeba Urfi, Income Tax Officer, 16Tf, Community Centre, Ward-7(4), C.R. Building, New Delhi Vs New Delhi-110002 Pan-Aaipu6601K Assessee Revenue Assessee By Shri Ved Jain, Adv. Shri Aayush Garg, Ca Revenue By Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing 23.12.2025 Date Of Pronouncement 16.01.2026

Section 10(1)Section 143(3)

order of the ld. CIT(A), the appellant has raised following grounds of appeal:- 1.1. That CIT(A) has erred in not accepting agricultural income amounting Rs.28,50,000 as income earned from agricultural activity and treating it income from undisclosed sources whereas the appellant is not engaged ... other business activities apart from agricultural activities 1.2. That CIT(A) has erred in sustaining disallowance of the entire expenses incurred for generating agricultural income amounting Rs.15,60,000 without understanding the facts of the case. 1.3. The CIT(A) has erred in accepting the fact put forth

Prem Lata Verma, Marris Road Aligarh vs. DCIT 4(1) (1), Aligarh

In the result, appeal preferred by assessee is allowed for statistical purposes

ITA 478/AGR/2025[2017-18]Status: DisposedITAT Agra15 Jan 2026AY 2017-18

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2017-18

Section 142(1)Section 144Section 147Section 68Section 80C

proceeded to make addition of Rs. 2 croes as unexplained credits u/s. 68 r.w.s. 115BBE of the Act. The AO also treated the declared agricultural income of Rs.15,00,000/- as income from other source and further disallowed the claim of Rs. 1,50,000/- made by assessee

Prem Lata Verma, Aligarh, Uttar Pradesh vs. DCIT, Circle 4(1)(1), Aligarh, Uttar Pradesh

In the result, assessee’s appeal is allowed

ITA 441/AGR/2025[2016-17]Status: DisposedITAT Agra15 Jan 2026AY 2016-17

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2016-17

Section 10(1)Section 139Section 144Section 147Section 148Section 234BSection 250Section 271(1)(c)Section 68

erred in law as well as on facts by upholding the addition of Rs. 15,00,000/- on account of agricultural income, without giving cognizance to the fact that the said amount qualifies as an exempt income u/s 10(1) of the Act, and was duly reported in the return

Sh. Devendra Dutt Pant, Haridwar vs. DCIT, Uttarkahand

Appeal is partly allowed in above terms

ITA 149/DDN/2025[2106-2017]Status: DisposedITAT Dehradun14 Jan 2026AY 2106-2017

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Salil Aggarwal, Sr. Adv. &For Respondent: Sh. A. S. Rana, Sr. DR
Section 133(6)Section 143(3)Section 54BSection 54E

question there was whether the income from forest land derived from sal and piyasal trees, 'not grown by human skill and labour' constitutes agricultural income? The decision that directly considered the issue, though under 5 Devendra Dutt Pant the Wealth-tax Act, 1957 is in CWT v. Officer-in-charge

Lawrence Swynen Berg, Haldwani vs. ITO Ward-2(1)(2), Haldwani

Appeal is partly allowed

ITA 118/DDN/2025[2017-18]Status: DisposedITAT Dehradun14 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman(Through Video Conferencing) Assessment Year: 2017-18 Sh. Lawrence Swynen Berg, Vs. Income Tax Officer, Foolchaur Manpur, Ward-2(1)(2), Dewalchaur, Haldwani, Haldwani Uttarakhand Pan : Bgqpb7590B (Appellant) (Respondent) Assessee By Sh. Prashant Kacker, Ca Department By Sh. Amar Pal Singh, Jcit (Dr)

Section 143(3)Section 69A

impugned addition. Suffice to say, the deceased assessee is stated to be a defence pensioner who had owned agricultural lands since having disclosed agricultural income therefrom to the tune of Rs.1,26,500/-. This was indeed coupled with his income disclosed from other sources amounted to Rs.1

Smt. Kusum Kujwal, Nainital vs. PCIT, Baireilly

Appeal is dismissed in above terms

ITA 102/DDN/2025[2020-21]Status: DisposedITAT Dehradun13 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: NoneFor Respondent: Ms. Poonam Sharma, CIT-DR
Section 2(14)(iii)Section 263Section 45(2)Section 50C

considered erroneous as pointed out in the show cause notice also: (i) The case was selected for scrutiny assessment to examine the issue of “Agricultural Income” for the A.Y 2020-21. (ii) During the assessment proceedings, the Assessing Officer passed the assessment order without making enquiries on the issue ... agricultural income claimed, which is received by selling the agricultural land into plots in square meter. The AO ignored the fact the assessee has changed the nature of land from agricultural to residential while selling the land in square meters. Further, the AO has failed to levy

Parmod Kumar Negi, Kinnaur vs. Income Tax Officer, Rampur Bushahr

The appeal stands allowed for statistical purposes

ITA 1291/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh13 Jan 2026AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1291/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2018-19) Shri Parmod Kumar Negi Ito Rampur Bushahar Ward No. 3 Barang, Kalpa, Barang, बनाम/ Vs. Himachal Pradesh - 172001 Kinnaur, Himachal Pradesh – 172107 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Afepn-8712-K (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. M.R. Sharma (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) - Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 12.01.2026 घोषणाकीतारीख /Date Of Pronouncement : 13.01.2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2018- 19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-02-2024 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] On Best Judgment Basis U/S 144 Of The Act On 23-05-2021. In The Assessment Order, Ld. Ao Made Considered Agricultural Income Of Rs.33,24,120/- As Income From Other Sources For Non-Compliance By The Assessee. The Ld.

For Appellant: Sh. M.R. Sharma (Advocate) – Ld. ARFor Respondent: Dr. Ranjit Kaur (Addl. CIT) - Sr. DR
Section 144

Assessing Officer [AO] on best judgment basis u/s 144 of the Act on 23-05-2021. In the assessment order, Ld. AO made considered agricultural income of Rs.33,24,120/- as income from other sources for non-compliance by the assessee. The Ld. 2 CIT(A) confirmed the assessment

Jamal Mohamed Haroon Hassan Moulana, Chennai vs. ITO, Ncw-1(1), Chennai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 2559/CHNY/2025[2021-22]Status: DisposedITAT Chennai13 Jan 2026AY 2021-22

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2559/Chny/2025 धििाजरण वर्ज /Assessment Year: 2021-22

For Appellant: Mr. Raghav Rajeev Menon &For Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 250Section 44ASection 69A

National Faceless Appeal Centre failed to appreciate that the appellant had duly explained the availability of cash as arising from (i) rental income, (ii) agricultural income, and (iii) retail business in fish and fish products (conducted primarily in cash) and from past savings, which were disclosed in the election affidavit ... auctions at seashore markets and re- auctions, thereby naturally resulting in accumulation of cash. 7. The National Faceless Appeal Centre failed to consider that agricultural income of ₹7,50,000/-was exempt under the Income Tax Act and could not be disregarded for the purpose of explaining cash availability

Khimji Lakhamshi Shah, Mumbai vs. Income Tax Officer Ward 30(1)(1), Mumbai

In the result the both the appeal of the assessee bearing ITA No

ITA 4455/MUM/2025[2016-17]Status: DisposedITAT Mumbai13 Jan 2026AY 2016-17

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Prayag JhaFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 147Section 250Section 68

made under section 68 of the Act related to unsecured loans amount to Rs.45,24,000/-, advance received amount to Rs.99,40,000/-, agricultural income 4,36,581/- and cash gift amount to Rs.10,00,000/-. The aggrieved assessee filed an appeal before

Khimji Lakhamshi Shah, Mumbai vs. Income Tax Officer, Ward 41(3)(4), Mumbai

In the result the both the appeal of the assessee bearing ITA No

ITA 4454/MUM/2025[2013-14]Status: DisposedITAT Mumbai13 Jan 2026AY 2013-14

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Prayag JhaFor Respondent: Shri Hemanshu Joshi (SR DR)
Section 143(3)Section 147Section 250Section 68

made under section 68 of the Act related to unsecured loans amount to Rs.45,24,000/-, advance received amount to Rs.99,40,000/-, agricultural income 4,36,581/- and cash gift amount to Rs.10,00,000/-. The aggrieved assessee filed an appeal before

Aparna Sinha, Haridwar vs. Income Tax Officer (AO), Haridwar

ITA 124/DDN/2025[2012-13]Status: DisposedITAT Dehradun12 Jan 2026AY 2012-13

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwalita No. 124 & Sa 14/Ddn/2025 : Asstt. Year: 2012-13 Aparna Sinha, Vs Income Tax Officer, R-207, Shivalik Nagar, Ranipur Income Tax Office, Gogi Range, Haridwar, Bhawan, Industrial Area, Uttarakhand-249403 Haridwar-224110 (Appellant) (Respondent) Pan No. Bjpps7235A Assessee By : Sh. Salil Kapoor, Adv. & Sh. Shivam Yadav, Adv. Revenue By : Sh. A. S. Rana, Sr. Dr Date Of Hearing: 12.01.2026 Date Of Pronouncement: 12.01.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal Ita No. 124/Ddn/2025 & Stay Application Sa No. 14/Ddn/2025 For Assessment Year 2012-13, Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1076298386(1) Dated 19.05.2025, In Proceedings U/S 144 Of The Income Tax Act, 1961. 2. Heard Both The Parties At Length. Case File Perused.

For Appellant: Sh. Salil Kapoor, Adv. &For Respondent: Sh. A. S. Rana, Sr. DR
Section 144Section 69A

dated 08.01.2026 inter alia placing on record her land ownership records as well as the crops grown thereupon that their cash deposits represent her agricultural income as well as past accumulated savings which could not have been treated as unexplained in both the lower proceedings. 5. The Revenue could hardly

Vachhani Ketanbhai Mansukhlal (HUF), Rajkot vs. The ITO Ward -1(1)(1), Rajkot

In the result, the appeal filed by the assessee, is partly allowed, in above terms

ITA 749/RJT/2025[2018-19]Status: DisposedITAT Rajkot12 Jan 2026AY 2018-19

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.749/Rjt/2025 िनधा"रण वष"/Assessment Year : 2018-19 बनाम/ Vachhani Ketanbhai The Income-Tax Officer, Vs Mansukhlal (Huf), Ward-1(1)(1), It Office, New Aayakar Bhavan, A/603 Rudrax Appartment, Vatiaka, Race Course Ring Road, Shree Colony Main Rajkot. – 360001, Gujarat Road, Amin Marg Rajkot 360005, (Gujarat) India "ायीलेखासं/.जीआइआरसं/.Pan/Gir No.: Aaghv1067A (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Ms. Devina Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 250

Appeals)- NFAC, Delhi erred in confirming the action of the assessing officer in making addition of Rs. 26,61,729/- by way of excess agriculture income, being difference between the gross agriculture receipts shown by the Appellant at Rs. 32,61,729/- and estimated ... Learned Commissioner of Income-tax (Appeals)- NFAC, Delhi erred in confirming the action of the assessing officer in estimating agricultural income without giving any basis of estimate. 3. The Learned Commissioner of Income-tax (Appeals)- NFAC, Delhi failed to appreciate that sale of agriculture produce was duly supported by invoices