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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

Nataraja Kailar, Bantwal vs. Income Tax Officer, Ward-2(1), Mangalore

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

ITA 96/BANG/2024[2017-18]Status: DisposedITAT Bangalore23 Feb 2024AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2017-18

For Appellant: Shri S. Srinivas Kamath, CAFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 142(1)Section 143(1)

brief facts of the case are that the assessee filed return of income declaring total income of Rs.1,42,040 and agricultural income of Rs.19,46,880. The return was processed u/s. 143(1) on 11.03.2018 resulting in ND. The case was selected for limited scrutiny of “Cash Page ... Karnataka Bank, Puttur and Rs.12,57,000 in Corporation Bank, Uppinangady. The assessee was asked to produce details of agricultural landholdings, agricultural income, expenses, and sources of cash deposits during demonetization period by notice u/s. 142(1) dated 29.08.2019. The assessee furnished reply. The AO noted that the total extent

Ramkunwar Patidar, Bhopal vs. The ITO 2 (4), Bhopal

Appeal is dismissed

ITA 208/IND/2022[2009-10]Status: DisposedITAT Indore22 Feb 2024AY 2009-10

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year : 2009-10 Shri Ramkunwar Patidar, Income-Tax Officer, Village Salliya, 2(4), बनाम/ Post Bawadia Kalan, Bhopal Vs. Bhopal (Appellant/Assessee) (Respondent/Revenue) Pan: Blxpp4909C Assessee By Shri S.S.Solanki, Ca & Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 15.01.2024 Date Of Pronouncement 22.02.2024

Section 143(3)Section 147Section 148Section 54F

appeal are such that the assessee-individual filed her original return of income on 31.03.2011 declaring total income of Rs. 1,86,150/- and agricultural income of Rs. 1,20,000/- which was assessed. In the return so filed, the assessee declared her 1/3rd share in taxable long-term capital

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2990/MUM/2023[2018-19]Status: DisposedITAT Mumbai22 Feb 2024AY 2018-19

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

Brief facts of the case shows that i. Assessee is an individual engaged in the business of brokerage, interest on savings account and agricultural income. ii. Search under Section 132 of the Act was 6th carried out on December, 2018, by investigation wing, New Delhi at the premises of locker ... placed in locker. vii. With respect to the source of ₹12 lacs, Assessee says that it is out of his savings from brokerage and agricultural income. He was also questioned that where his annual income is only ₹3 lacs how ₹14 lacs in denomination of new notes of ₹2000 were

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2989/MUM/2023[2019-20]Status: DisposedITAT Mumbai22 Feb 2024AY 2019-20

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

Brief facts of the case shows that i. Assessee is an individual engaged in the business of brokerage, interest on savings account and agricultural income. ii. Search under Section 132 of the Act was 6th carried out on December, 2018, by investigation wing, New Delhi at the premises of locker ... placed in locker. vii. With respect to the source of ₹12 lacs, Assessee says that it is out of his savings from brokerage and agricultural income. He was also questioned that where his annual income is only ₹3 lacs how ₹14 lacs in denomination of new notes of ₹2000 were

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2988/MUM/2023[2015-16]Status: DisposedITAT Mumbai22 Feb 2024AY 2015-16

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

Brief facts of the case shows that i. Assessee is an individual engaged in the business of brokerage, interest on savings account and agricultural income. ii. Search under Section 132 of the Act was 6th carried out on December, 2018, by investigation wing, New Delhi at the premises of locker ... placed in locker. vii. With respect to the source of ₹12 lacs, Assessee says that it is out of his savings from brokerage and agricultural income. He was also questioned that where his annual income is only ₹3 lacs how ₹14 lacs in denomination of new notes of ₹2000 were

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2987/MUM/2023[2017-18]Status: DisposedITAT Mumbai22 Feb 2024AY 2017-18

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

Brief facts of the case shows that i. Assessee is an individual engaged in the business of brokerage, interest on savings account and agricultural income. ii. Search under Section 132 of the Act was 6th carried out on December, 2018, by investigation wing, New Delhi at the premises of locker ... placed in locker. vii. With respect to the source of ₹12 lacs, Assessee says that it is out of his savings from brokerage and agricultural income. He was also questioned that where his annual income is only ₹3 lacs how ₹14 lacs in denomination of new notes of ₹2000 were

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2986/MUM/2023[2016-17]Status: DisposedITAT Mumbai22 Feb 2024AY 2016-17

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

Brief facts of the case shows that i. Assessee is an individual engaged in the business of brokerage, interest on savings account and agricultural income. ii. Search under Section 132 of the Act was 6th carried out on December, 2018, by investigation wing, New Delhi at the premises of locker ... placed in locker. vii. With respect to the source of ₹12 lacs, Assessee says that it is out of his savings from brokerage and agricultural income. He was also questioned that where his annual income is only ₹3 lacs how ₹14 lacs in denomination of new notes of ₹2000 were

Pawan Jajoo, Mumbai vs. ITO Ward (7) (4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2985/MUM/2023[2013-14]Status: DisposedITAT Mumbai22 Feb 2024AY 2013-14

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

Brief facts of the case shows that i. Assessee is an individual engaged in the business of brokerage, interest on savings account and agricultural income. ii. Search under Section 132 of the Act was 6th carried out on December, 2018, by investigation wing, New Delhi at the premises of locker ... placed in locker. vii. With respect to the source of ₹12 lacs, Assessee says that it is out of his savings from brokerage and agricultural income. He was also questioned that where his annual income is only ₹3 lacs how ₹14 lacs in denomination of new notes of ₹2000 were

Shri Pawan Jajoo, Mumbai vs. Income Tax Office (7)(4), Mumbai

In the result, all 7 appeals filed by the assessee are allowed

ITA 2984/MUM/2023[2014-15]Status: DisposedITAT Mumbai22 Feb 2024AY 2014-15

Bench: Shri Amit Shukla, Am & Shri Prashant Maharishi, Am

For Appellant: Shri S.L. Jain, ARFor Respondent: Shri Jagdish Jangid, CIT DR
Section 131Section 132Section 132(4)Section 133(6)Section 69A

Brief facts of the case shows that i. Assessee is an individual engaged in the business of brokerage, interest on savings account and agricultural income. ii. Search under Section 132 of the Act was 6th carried out on December, 2018, by investigation wing, New Delhi at the premises of locker ... placed in locker. vii. With respect to the source of ₹12 lacs, Assessee says that it is out of his savings from brokerage and agricultural income. He was also questioned that where his annual income is only ₹3 lacs how ₹14 lacs in denomination of new notes of ₹2000 were

Hitendra Dilipsinh Jadeja, Ahmedabad vs. The Income Tax Officer, Ward-3(2)(2), Ahmedabad

In the result, the appeal filed by the assessee is dismissed

ITA 66/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad21 Feb 2024AY 2017-18

Bench: Smt.Annapurna Gupta & Ms. Suchitra Kambleassessment Year : 2017-18 Hitendra Dilipsinh Jadeja The Ito 4, Sanjay Park Society Vs Ward-3(2)(2) Nr.Jogni Mata Temple Ahmedabad Sanand Ahmedabad – 382 110 Gujarat Pan: Agfpj1666A अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : None Revenue By : Ms.Saumya Pandey Jain, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 14/02/2024 घोषणा क" तार"ख /Date Of Pronouncement: 21/02/2024 आदेश/O R D E R Per Ms. Suchitra Kamblethis Appeal Is Filed By The Assessee Against The Order Dated 19/10/2022 Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As “Cit(A)” In Short] For Assessment Year (Ay) 2017-18. 2. Grounds Of Appeal Are As Under:

For Appellant: NoneFor Respondent: Ms.Saumya Pandey Jain, Sr.DR
Section 234ASection 250(6)Section 44ASection 68

erred both in law and on the facts by confirming addition of Rs.9,72,300/- as unexplained agriculture income u/s 68 of the Act without taking into account the arguments of the appellant. Thus, Hon'ble CIT(A) has not taken into account the details submitted by the appellant ... various dates, the Assessing Officer made addition of Rs.31,30,000/- towards cash receipts from Shri Devendra D.Jadeja, addition of Rs.9,72,300/- towards agricultural income, addition of Rs.18,74,226/- towards Short Term Capital Gain (STCG) on sale of land and estimated the addition of Rs.3 Lakhs Hitendra Dilipsinh

Mr. Duraisamy Arun Prasath, Chennai vs. ITO, Non Corporate Ward 4(2), Coimbatore

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

ITA 1553/CHNY/2023[2017-18]Status: DisposedITAT Chennai21 Feb 2024AY 2017-18

Bench: Shri Mahavir Singhआयकर अपील सं./Ita No.: 1553/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18 Shri Duraisamy Arun Prasath, Vs. The Income Tax Officer, C/O. M/S. S. Sathiyanarayanan, Non-Corp Ward 4(2), Advocates, Coimbatore. F1, Prp Block – Rose Park, No.10, Santhi Nagar, 1St Cross, Adambakkam, Chennai – 600 088. [Pan: Bdapa 6265R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri S. Sathyanarayanan, Advocate ""यथ" क" ओर से /Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 21.02.2024 घोषणा क" तारीख /Date Of Pronouncement : 21.02.2024 आदेश/ O R D E R

For Appellant: Shri S. SathyanarayananFor Respondent: Shri D. Hema Bhupal, JCIT
Section 115BSection 144Section 69A

parte and that of the AO is of best judgment assessment framed u/s.144 of the Act, due to non filing of evidence of agricultural income of earlier years. The ld.counsel stated that practically both the orders i.e., of the AO and CIT(A) is ex-parte and without allowing opportunity ... acres of agricultural land. The assessee has given various details i.e, adangal plus chitta and details of agricultural crops grown and quantum of agricultural income. But the AO noted that assessee is an agriculturist and does farming in his own land as well as 11 acres of leased land

Kondichetty Venkatasweamy Janarthanam, Chennai vs. ITO, Non-Corporate Ward-4(2), Chennai

In the result, the appeal filed by the assessee is allowed

ITA 1478/CHNY/2023[2017-18]Status: DisposedITAT Chennai21 Feb 2024AY 2017-18

Bench: Shri Mahavir Singh

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT
Section 115BSection 143(3)Section 69

hence need not be reproduced. 3. Brief facts are that the assessee is a real estate broker earning commission income and also declaring agricultural income. The assessee filed his return of income for the relevant assessment year 2017-18 on 20.07.2017 declaring total income at Rs.4,08,140/-. The assessee

Shri. B.S.Ramachandra, Periyapatna vs. Assistant Commissioner of Income-Tax, Circle-1(1) & Tps, Mysore

In the result, appeal filed by the Assessee stands allowed for

ITA 897/BANG/2023[2017-18]Status: DisposedITAT Bangalore21 Feb 2024AY 2017-18

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year: 2017-18

For Appellant: Ms. Sunaiana Bhatia, Ld. CAFor Respondent: Shri Subramanian. S, Ld. JCIT
Section 115BSection 144Section 250Section 69A

furnish his reply by not later than 04.12.2019. The said notice also remain un-complied with. Therefore, the AO ultimately held the agricultural income of Rs.22,65,491/- as unexplained income and added back to the total income of the Assessee under the head ‘income from other sources

Ram Dhan Yadav, Chomu Jaipur vs. Income Tax Officer, ITO 7(3), Jaipur

In the result, both the appeals of the assessee are allowed

ITA 369/JPR/2023[2008-09]Status: DisposedITAT Jaipur20 Feb 2024AY 2008-09

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

loans) 1,30,50,000/- 6. As discussed in para 13above. (Intt. O.S.) 3,08,080/- Total income 1,37,03,680/- Agricultural income 1,00,000/- 7. Aggrieved from the order of the assessing officer, assessee preferred an appeal before the ld. CIT(A). The appeal of the assessee

Ram Dhan Yadav, Chomu Jaipur vs. ITO, WD 7(3), Jaipur

In the result, both the appeals of the assessee are allowed

ITA 366/JPR/2023[2007-2008]Status: DisposedITAT Jaipur20 Feb 2024AY 2007-2008

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajesh Soni (C.A.)For Respondent: Shri Anoop Singh (Addl.CIT)
Section 143(3)Section 144Section 147Section 148Section 69B

loans) 1,30,50,000/- 6. As discussed in para 13above. (Intt. O.S.) 3,08,080/- Total income 1,37,03,680/- Agricultural income 1,00,000/- 7. Aggrieved from the order of the assessing officer, assessee preferred an appeal before the ld. CIT(A). The appeal of the assessee

Madan Mohan Mishra, Mumbai vs. ITO 8(2)(4), Mumbai

Appeal is allowed for statistical purposes

ITA 795/MUM/2023[2011-12]Status: DisposedITAT Mumbai19 Feb 2024AY 2011-12

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri S.L. JainFor Respondent: Smt. Mahita Nair
Section 142Section 143(2)Section 143(3)Section 250Section 271(1)(c)Section 54

assessee has raised the following grounds:– “(1) The learned commissioner of income tax (appeal)-17 has erred in law, in confirming the addition of agricultural income as a undisclosed sours of Rs.2270575/-which is arbitrary and unjustified. Shri Madan Mohan Mishra ITA no.795/Mum./2023 (2) The learned commissioner of income ... most arbitrary and unjustified.” 3. The issue arising in ground No. 1, raised in assessee’s appeal, pertains to addition on account of agricultural income. 4. The brief facts of the case pertaining to this issue, as emanating from the record, are: The assessee is an individual

The DCIT, Central Circle-2, Vadodara vs. Shri Pravinchandra Ranchhodbhai Patel, Vadodara

In the result, the appeal of the Revenue is dismissed

ITA 46/AHD/2023[2014-15]Status: DisposedITAT Ahmedabad15 Feb 2024AY 2014-15

Bench: Mrs. Annapurna Gupta & Ms. Suchitra R. Kambleिनधा"रण वष"/Assessment Year: 2014-15 Shri Pravinchandra The Deputy Commissioner Of Ranchhodbhai Patel, Income-Tax, Vs. 52, Sarvodaya Society, Central Circle-2, Nizampura, Vadodara Vadodara Pan : Acppp 2695 F अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Jigar Adhyaru, Ar Revenue By : Shri Ashok Kumar Suthar, Sr Dr सुनवाई क" तारीख/Date Of Hearing : 12.02.2024 घोषणा क" तारीख /Date Of Pronouncement: 15.02.2024 आदेश/O R D E R आदेश आदेश आदेश Per Annapurna Gupta:

For Appellant: Shri Jigar Adhyaru, ARFor Respondent: Shri Ashok Kumar Suthar, Sr DR
Section 132Section 139(1)Section 153ASection 250(6)Section 271(1)(c)

total assessed income of Rs.10,32,17,140/- after making various additions/disallowances, which included the addition of Rs. 4,48,600/- on account of agricultural income, Rs.4,00,84,234/- for credit entries from Bank Statements, Rs. 5,58,300/- for unexplained income, Rs. 2,51,180/- for unaccounted income ... order, assessee preferred appeal before the ld. CIT(A) who, partly allowed the appeal of the assessee; however, confirmed the additions on account of agriculture income of Rs.4,00,000/-, credit entries in bank account of Rs.26,63,386/-, unexplained loan/investment amounting to Rs.3,67,37,485/- and unaccounted income

Nanjappa Gounder Palanisamy, Coimbatore vs. ITO, Non Corporate Ward-3(2), Coimbatore

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

ITA 1227/CHNY/2023[2017-18]Status: DisposedITAT Chennai13 Feb 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.1227/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18

For Appellant: Shri Shrenik Chordia, CAFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 131Section 143(1)Section 143(3)Section 68

assessee and moreover, she has not filed any ROI. During the course of scrutiny proceedings, the assessee has also not furnished any details towards agricultural income. Against the final show cause notice, the assessee has submitted that he offered an income of ₹.1.06 crores under PMGKY and paid the taxes

Arun Singh Yadav, Village Akera Po Dahruhera vs. Assessing Officer, Rewari

The appeal is allowed for statistical purposes

ITA 1488/DEL/2021[2015-16]Status: DisposedITAT Delhi09 Feb 2024AY 2015-16

Bench: Shri G.S. Pannu & Shri Anubhav Sharma(Through Hybrid Mode)

Section 143(3)

enhanced to Rs. 57,18,360/-. Learned CIT(A) has sustained the addition with relief of Rs. 1,00,000/- on account of agriculture income to the assessee. 4. As assessee has challenged the impugned order of learned CIT(A), it came up during hearing that the assessee had filed ... submitted that the assessee had income from business in form of job work charges which was deposited in the bank accounts apart from agricultural income for which benefit is given by the learned CIT(A). It was submitted that assessee also had received certain cash assistance from the mother

Mani Sundaram, Devakottai vs. ITO, Ward-1, Karaikudi

In the result, we are of the considered view that the case on hand does not warrant levy of penalty under Section 271D of the Act

ITA 899/CHNY/2023[2017-18]Status: DisposedITAT Chennai07 Feb 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.899/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18 Mani Sundaram, Vs. The Income Tax Officer, No. 52, Thiyagigal Road, Ward-1, Karaikudi. Devakottai, Tamil Nadu 630 302. [Pan:Cwops9124D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 01.02.2024 घोषणा की तारीख /Date Of Pronouncement : 07.02.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, Dated 21.06.2023 Relevant To The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is A Proprietor Of M/S. Surabi Pvc Pipes & Filed The Return Of Income For The Assessment Year 2017-18 On 20.01.2018 Declaring Taxable Income Of ₹.3,03,720/-. The Return Of Income Was Processed Under Section 143(1) Of The Income Tax

For Appellant: Shri T. Vasudevan, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 143(1)Section 269SSection 271DSection 274

loan from Pandiyammal (Mother) 3. ₹.1,17,550/- cash loan from father-in-law (Sathaiah) 4. ₹.2,75,000/- cash received out of the agricultural income Since the Assessing Officer was of the opinion that the assessee has availed cash loan in contravention of provision of section 269SS