“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

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

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

Hemant Kumar Tikariha, Raipur vs. ITO, Ward-1(1), Raipur

In the result, appeal of the assessee in ITA No

ITA 97/RPR/2026[2011-12]Status: DisposedITAT Raipur25 Feb 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.97 & 98/Rpr/2026 "नधा"रण वष" /Assessment Years : 2011-12 & 2012-13

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 69Section 69A

carefully examined. The appellant has furnished a cash book in support of the sources of cash deposits, claiming receipts from contract work, gold loan, agricultural income, and a gift received from her mother. The cash book and supporting documents submitted in this regard have been perused in detail ... remains unsubstantiated and is accordingly treated as the appellant's own unexplained money. 5.5 The appellant has further claimed that the cash deposits represent agricultural income and has relied upon a certificate issued by Jila Sahakari Bank stating that the deposits were out of sale proceeds of agricultural produce. However

Pratibha Singh, Shimla vs. ACIT Circle, Circle Shimla

In the result, the appeal of the assessee is dismissed

ITA 860/CHANDI/2025[2009-10]Status: DisposedITAT Chandigarh25 Feb 2026AY 2009-10

Bench: The Hon’Ble High Court. The Hon’Ble High Court Upheld The Validity Of Assumption Of Jurisdiction Holding That The Assessing Officer Possessed

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aman Singhi, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 143(3)Section 147Section 69

bank transactions could exist prior to execution of the MOU and those appeals were dismissed. 7. The Assessing Officer also rejected the plea of agricultural income observing that mere ownership of orchard land does not establish generation of liquid funds and that such agricultural income had not been accepted ... pressing any other ground raised in the memo of appeal. The Ld. AR reiterated that the investment was made out of the agricultural income of the HUF routed through Shri Anand Chauhan under an orchard management arrangement and not by the assessee in her individual capacity. It was argued that

Sivakumar, Dindigul vs. Income Tax Officer, Ward 1, Dindigul

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

ITA 3580/CHNY/2025[2015-16]Status: DisposedITAT Chennai25 Feb 2026AY 2015-16

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.3580/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Sivakumar, Vs. The Income Tax Officer, 2-114-1, North Street, M. Kurumbapatti, Ward 1, Nilakkottai Tk, Dindigul 624 202. Dindigul. [Pan: Fkcps0842D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Venkataraman, Ca ""थ" की ओर से/Respondent By : Shri Sbr Kumar Laghimsetti, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.01.2026 घोषणा की तारीख /Date Of Pronouncement 25.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.09.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2015-16. 2. At The Outset, We Find That Out Of Total Credits Reflected In Bank Accounts Of ₹.76,95,084/- & The Assessing Officer Accepted The Explanations Offered By The Assessee For The Sources For Credits To An Extent Of ₹.23,17,258/- Relates To Sale Made During The Year Under 2

For Appellant: Shri R. Venkataraman, CAFor Respondent: Shri SBR Kumar Laghimsetti, Addl. CIT

agricultural produce. We find that as contented by the ld. AR that the assessee’s main business is buying and selling of flowers and agricultural income from 30 acres of agricultural land owned by the assessee and his relatives and we find no adverse findings recorded by the Assessing Officer

Shree Ganesh Builders Ltd., Nagpur vs. DCIT, Circle 1, Nagpur

ITA 626/NAG/2024[2014-15]Status: DisposedITAT Nagpur24 Feb 2026AY 2014-15

Bench: Shri Pawan Singh, Jm & Shri Khettra Mohan Roy, Am

For Appellant: Shri Himesh Demble, CAFor Respondent: Shri Surjit Kumar Saha

Section 143(3)Section 40A(3)

purchase of agricultural land and an amount of 3,83,800/- was added to the income of the assessee company on account of agricultural income. During the year under consideration the assessee company has purchased agricultural land bearing Khasra No. 97/2, Sheet No.942/20 City Survey No.8, 80 Mouza Nari,Nagpur

Shree Ganesh Builders Ltd., Nagpur vs. DCIT, Circle 1, Nagpur

ITA 625/NAG/2024[2013-14]Status: DisposedITAT Nagpur24 Feb 2026AY 2013-14

Bench: Shri Pawan Singh, Jm & Shri Khettra Mohan Roy, Am

For Appellant: Shri Himesh Demble, CAFor Respondent: Shri Surjit Kumar Saha

Section 143(3)Section 40A(3)

Dharmender Chauhan, Shimla vs. Income Tax Officer, Shimla

The appeal stand allowed for statistical purposes

ITA 189/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh24 Feb 2026AY 2016-17

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.189/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2016-17) Shri Dharmender Chauhan Ito Ward-01 Flat No. 101, Income Tax Department, बनाम/ Vs. Surya Dharshan Building Railway Board Building, North Oak, Sanjauli, Himachal Pradesh - 171003 Himachal Pradesh - 171006 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bglpd-8051-N (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Vishal Mohan (Sr. Advocate) With Ms. Isha Sharma (Advocate) & Sh. Parveen Sharma (Advocate) – Ld. Ars ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 24-02-2026 घोषणाकीतारीख /Date Of Pronouncement 24-02-2026 : आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2016-17 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 28-04-2023 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 22-11-2018. The Registry Has Noted Delay Of 587 Days In The Appeal

For Appellant: Sh. Vishal Mohan (Sr. Advocate) with Ms. Isha Sharma (Advocate) and Sh. Parveen For Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR

Section 143(3)

order was not in the knowledge of the assessee. 2. In the assessment order, Ld. AO made addition of Rs.42,41,712/- by rejecting agricultural income claim of the assessee. The assessee could not substantiate the same. The Ld. CIT(A) confirmed the assessment for the same very reasons. Aggrieved

Mahendra Kumar Jagtaji, Salem vs. The Deputy Commissioner of Income Tax, Central Circle, Salem

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

ITA 1861/CHNY/2025[2020-21]Status: DisposedITAT Chennai23 Feb 2026AY 2020-21

Bench: Shri Manu Kumar Giri & Shris.R.Raghunathaआयकरअपीलसं. Ita No. 1861/Chny/2025 & Sa 69/Chny/2025 "नधा"रणवष"/Assessment Years: 2020-21 Mahendra Kumar Jagtaji, V. Dcit, Central Circle, 6/21, Devanayagam Pillai, Salem-636007 St. Shevapet, Salem-636002 [Pan: Apopm 3624 H] (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Appellant: Mr. Jaydip Desai, C.AFor Respondent: Mr. Shiva Srinivas, CIT

Section 131Section 132Section 143(2)Section 143(3)Section 153ASection 270ASection 271ASection 69A

learned CIT(A) has failed to appreciate that the cash seized to the extent of Rs.6,90,000/-was duly explained from agricultural income, supported by sale bills, land ownership records, and other corroborative documents, and rejection of such evidence is arbitrary, baseless, and against the principles of natural justice ... genuineness of the donors. 4. The learned CIT(A) has erred in placing unwarranted reliance on presumptions, conjectures, and surmises in disregarding the agricultural income and gifts, contrary to settled judicial precedents that no addition can be made merely based on assumptions. 5. The learned CIT(A) has erred

Rathinampillai Nagarajan, Trichy vs. Income Tax Officer, Ward 2(1), Trichy, Cantonment Trichy

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

ITA 4085/CHNY/2025[2020-21]Status: DisposedITAT Chennai20 Feb 2026AY 2020-21

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 4085/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Shri Rathinampillai Nagarajan, The Income Tax Officer, No.72, Ashok Nagar, Vs. Ward 2(1), R.M.S. Colony, Trichy. Karumandapam, Trichy – 620 001. Pan: Ceypn 6032D (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri M.K. Rangaswamy, Ca ""यथ" क" ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई क" तारीख/Date Of Hearing : 18.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 20.02.2026

For Appellant: Shri M.K. Rangaswamy, CAFor Respondent: Ms. V. Aswathy, JCIT

Section 250

notices issued from the office of the First Appellate Authority. 3. The Ld.AR submitted that the assessee is an agriculturist. The assessee claimed gross agricultural income of Rs.39,62,750/- after incurring expenditure of Rs.5,98,050/- and had disclosed net agricultural income of Rs.33,64,700/-. During the course ... assessment proceedings, assessee was directed to explain the receipt of agricultural income. In response to show-cause notice issued, assessee had submitted partial details / evidence in support of holding agricultural land, etc. However, no details were furnished with regard to earning of agricultural income to the extent of gross agricultural

Manish Kumar Gupta, Narsinghpur vs. Income Tax Officer Ward, Narsinghpur

In the result, the appeal is partly allowed for statistical purposes

ITA 1/JAB/2025[2017-18]Status: DisposedITAT Jabalpur19 Feb 2026AY 2017-18

Bench: Shri Anadee Nath Misshra

decision to the discretion of the Bench. On perusal of the assessment order, it is found that the assessee has been regularly declaring agricultural income in earlier years as well. However, in the present assessment order, addition is the result of the fact that the assessee’s submissions with regard ... agricultural income were not considered favourably by the Assessing Officer in entirety. Further, the assessee’s submissions were rejected without affording reasonable opportunity to the assessee. The impugned appellate order passed by the Ld. CIT(A) was also passed without providing reasonable opportunity to the assessee. In view

Akhilesh Parmar, Indore vs. Income Tax Officer, Indore

Appeal is allowed for statistical purpose

ITA 636/IND/2025[2017-18]Status: DisposedITAT Indore19 Feb 2026AY 2017-18

Bench: Shri B.M. Biyani

Section 143(3)Section 253(5)

made in assessee’s bank a/c. Ld. AR narrated that the assessee explained three sources of impugned deposits to the AO, namely (i) the agricultural income earned by assessee, (ii) the cash received by assessee on death of father on 20.09.2016, and (iii) the re-deposit of previous cash withdrawals ... assessee from his bank a/cs. However, the AO has given estimated credit of Rs. 2,50,000/- only from first source i.e. the agricultural income and made addition of Rs. 10,00,000/-. The AO has not given any credit of the second source for lack of documentary evidence

Jethabhai Gokulbhai Gol, Banaskatha vs. ITO, Ward 1, Palanpur, Banaskantha

Accordingly, the appeal filed by the assessee is dismissed

ITA 2668/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Chetan Agarwal, ARFor Respondent: Shri Rajenkumar M Vasavda, Sr. DR

Section 142(1)Section 144BSection 147Section 148Section 69

each explanation offered by the assessee. The assessee claimed that the capital introduced was sourced from opening cash balance, cash sales from potato trading, agricultural income, and milk sale income. The CIT(Appeals) noted that the assessee relied heavily on unaudited and self-prepared documents and that no contemporaneous ... assessee had failed to furnish corroborative evidence such as quantity supplied, rates, receipts, or expenditure details, rendering the claim unverifiable. Similarly, the claim of agricultural income was rejected on the ground that no land records, crop details, sale bills, or evidence of agricultural expenses were produced. 8. After considering

Gujarat State Cooperative Cotton Federation Limited, Ahmedabad vs. The Pr. CIT, Ahmedabad -1, Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 538/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad19 Feb 2026AY 2018-19

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2018-19

For Appellant: Shri Manish J. Shah &For Respondent: Shri Sher Singh, CIT-D.R

Section 139(1)Section 143Section 143(3)Section 263Section 56Section 80PSection 80P(2)Section 80P(2)(a)Section 80P(2)(d)

submitted that the assessee invested in the commercial banks and earned interest income which cannot be treated as agricultural income or the income derived from the contribution of the members of the society (assessee federation). The original FDR amount can be the contribution but the interest derived from the same

Balaraj, Bengaluru vs. Income Tax Officer, Ward-6(1)(1), Bangalore

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

ITA 1979/BANG/2025[2017-18]Status: DisposedITAT Bangalore19 Feb 2026AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Shri Ravishankar, Advocate

Section 133(6)Section 142(1)Section 143(2)Section 69A

issued on 13/08/2018. Thereafter notice u/s. 142(1) was issued calling for some details about the rental Page 2 of 4 incomes and the agricultural incomes. The AO had also sought for/. the details about the cash deposits made during the demonetisation period by issuing letter

Karamjit Singh Toor, Ludhiana vs. Jao the Income Tax Officer Ward 3, Khanna

The appeal stand allowed for statistical purposes

ITA 1527/CHANDI/2025[2018-2019]Status: DisposedITAT Chandigarh18 Feb 2026AY 2018-2019

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.1527/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) Shri Karamjit Singh Toor Ito Village Barmalipur, Near Bija बनाम/ Vs. Ward-3 Ludhiana – 141416 Khanna - 141401 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Fmpps-8259-R (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) - Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 17.02.2026 घोषणाकीतारीख /Date Of Pronouncement : 18.02.2026 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 Dated 16-01-2025 In The Matter Of An Assessment Framed By Ld. Ao On Best Judgment Basis U/S 144 On 19-04-2021. In The Assessment Order, Ld. Ao Made Addition Of Rs.40.16 Lacs Which Represent Agricultural Income As Shown By The Assessee. The Assessee Failed To Make Any Representation During Assessment

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) - Sr. DR

Section 144

best judgment basis u/s 144 on 19-04-2021. In the assessment order, Ld. AO made addition of Rs.40.16 Lacs which represent agricultural income as shown by the assessee. The assessee failed to make any representation during assessment proceedings. The Ld. CIT(A) did not condone the delay

Bhikhabhai Somabhai Patel, Sabarkantha vs. The ITO, Ward-1, Himatnagar

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 2597/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2018-19

For Appellant: Shri S. N. Divatia & Shri Samir VoraFor Respondent: Shri Rajkumar M Vasavda, Sr. DR

Section 144Section 270ASection 57

agriculturist, who has always been protected from payment of taxes by the law makers, requiring no taxes to be paid on his meagre agricultural income, would be burdened with a tax liability of Rs.1 Cr., that too without the assessee being heard at all and without the issue at hand

Bhikhabhai Somabhai Patel, Sabarkantha vs. The ITO, Ward-1, Himatnagar

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 2596/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad18 Feb 2026AY 2018-19

For Appellant: Shri S. N. Divatia & Shri Samir VoraFor Respondent: Shri Rajkumar M Vasavda, Sr. DR

Section 144Section 270ASection 57

Laxmanrao Akaram Patil, Tasgaon vs. DCIT, Sangli

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

ITA 588/PUN/2025[2017-18]Status: DisposedITAT Pune18 Feb 2026AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Umesh Kumar M MaliFor Respondent: Shri Uodol Raj Singh

Section 143(2)Section 144

facts and circumstances of the case the Learned Assessing Officer has erred to make addition of Rs. 2,03,870/- being agriculture income without considering the fact that said agri income was banking channel and its genuine sources received through 4.1) Learned A.O. has made an addition ... being cash deposited in his bank accounts during demonetization and also includes addition of Rs. 2,03,870/- on account of unexplained agricultural income. 4 5. Being aggrieved with the above ex parte assessment order the assessee preferred an appeal before the learned CIT appeal. The appeal was dismissed

Avijit Gorain, Durgapur vs. I.T.O., Ward - 2(4), Durgapur

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

ITA 2398/KOL/2025[2015-2016]Status: DisposedITAT Kolkata18 Feb 2026AY 2015-2016

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Avijit Gorain…………….....……..………………….……….……….……Appellant C/O Jain Vinod & Associates, 41A, Ajc Bose Road, Diamond Prestige Nirman, Suite 613, 6Th Floor, Kolkata-700017. [Pan: Aqvpg8082F] Vs. Ito, Ward-2(4), Durgapur…...……...…………………….....……...…..…..Respondent Appearances By: Shri Vinod Kr. Jain, Ar, Appeared On Behalf Of The Appellant. Shri Aditya Bikram, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 05, 2026 Date Of Pronouncing The Order : February 18, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 25.08.2025 Of The Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015– 16. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & He Did Not File Any Return Of Income. As Per Information Received By The Assessing Officer, The Assessee Made Transactions In Selling Immovable Property Of Rs.89,46,452/- & Transfer Of Capital Assets Of Rs.31,97,560/-. Due To Absence Of Supporting Documents Or Explanations From The Assessee, The Assessing Officer Added Avijit Gorain Rs.1,21,44,012/- (Rs.89,46,452/- & Rs.31,97,560/-) By Passing An Order U/S 144 R.W.S. 147 R.W.S. 144B Of The Act.

Section 144Section 147Section 250

that the ld. CIT(A) in para 6.2.4 of the impugned order has itself mentioned that there no sufficient evidences of cultivation, cropping or agricultural income were submitted to substantiate the claim of the assessee. Learned CIT(A) has further held that there is no evidence of compulsory acquisition

Kamleshkumar Dhansukhlal Patel, Valsad vs. ITO, Ward 2, Valsad

In the result, the appeal of the assessee is allowed

ITA 890/SRT/2025[2020-21]Status: DisposedITAT Surat17 Feb 2026AY 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 143(2)Section 144Section 250Section 69

just and proper on the facts of the case and in law in confirming the addition of Rs.66,52,171/- on A/c of Agriculture Income. Wrongly declared for typographic mistake.” 3. The pertinent facts required for adjudication of this case are that the assessee is an individual and filed ... year under Kamleshkumar Dhansukhlal Patel Vs. ITO Asst. Year : 2020-21 - 2– consideration on 21.01.2021, declaring total income at Rs.73,000/- and agricultural income of Rs.67,91,924/-. The case was selected for ‘Limited Scrutiny’ under CASS on the issue of “Agricultural Income’. Since the assessee has failed to comply

Dilipkumar Dahyabhai Patel, Na vs. Arivs.Income Tax Officer, Ward-2, Navsari

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

ITA 62/SRT/2024[ 2011-12]Status: DisposedITAT Surat17 Feb 2026

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं /Ita No.62/Srt/2024 िनधा"रण वष" /Assessment Year : 2011-12 Dilipkumar Dahyabhai Patel The Income Tax Officer बनाम/ Moti Kanbiwad Tankal Ward-2 V/S. Tal. Chikhli Navsari Navsari – 396 560 "थायी लेखा सं./Pan: Asipp 6274 H (अपीलाथ(/ Appellant) (!) यथ(/ Respondent) Assessee By : Shri Hardik Vora, Ar Revenue By : Shri Ajay Uke, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 19/11/2025 घोषणा की तारीख /Date Of Pronouncement: 17/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 23/11/2023 For The Assessment Year (Ay) 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit (Appeals) Has Erred In Confirming The Addition Of Rs.17,00,000/- On Account Of Unexplained Cash Deposit. Dilipkumar Dahyabhai Patel Vs. Ito Asst. Year : 2011-12 2 2. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit (Appeals) Has Erred In Not Accepting Additional Evidences As Per Rule 46A Of Income Tax Rules, 1962. 3. On The Facts & Circumstances Of The Case As Well As Law On The Subject, The Learned Cit (Appeals) Has Erred In Not Considering That Cash Deposits In Bank Account Are On Account Of Agricultural Income.

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Ajay Uke, Sr.DR

Section 147

subject, the learned CIT (Appeals) has erred in not considering that cash deposits in bank account are on account of agricultural income. 4. It is therefore prayed that the above addition/disallowance made by the assessing officer may please be deleted. 5. Appellant craves leave to add, alter or delete