“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

Assistant Commissioner of Income-Tax, Central Circle - 1, Aurangabad vs. M/S. M.B. Patil Construction Ltd, Aurangabad

In the result, the cross appeal filed by the Revenue in ITA

ITA 2078/PUN/2017[2013-14]Status: DisposedITAT Pune05 May 2025AY 2013-14

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Kalrav MehrotraFor Respondent: Shri Ajay Kumar Keshari &

Section 143(2)Section 143(3)Section 2(22)(e)Section 40A(3)Section 68Section 801ASection 80I

Rs.5,12,194/-, (b) Interest income of Rs.53,32,948/- which remained to be added back by the assessee, (c) Disallowance of agricultural income of Rs.6,00,000/-, (d) Disallowance of other expenses of Rs.35,00,000/-, (e) Deemed dividend u/s 2(22)(e) of Rs.49 ... appeal, after considering the reply of the assessee, Ld. CIT(A) reduced the addition made u/s 68 of the IT Act on account of agricultural income of Rs.6,00,000/- to Rs.3,00,000/-, Ld. CIT(A) also reduced the addition made on account of other expenses of Rs.35

M/S. M.B.Patil Constructions Ltd, Aurangabad vs. Deputy Commissioner of Income-Tax, Central Circle - 1, Aurangabad

In the result, the cross appeal filed by the Revenue in ITA

ITA 2058/PUN/2017[2013-14]Status: DisposedITAT Pune05 May 2025AY 2013-14

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Kalrav MehrotraFor Respondent: Shri Ajay Kumar Keshari &

Section 143(2)Section 143(3)Section 2(22)(e)Section 40A(3)Section 68Section 801ASection 80I

Palanisamy Devi, Erode vs. ACIT, Circle-1, Erode

In the result, appeal filed by the assessee is allowed

ITA 42/CHNY/2025[2013-14]Status: DisposedITAT Chennai05 May 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. P.M.Kathir, AdvocateFor Respondent: Ms. Anitha, Addl.CIT

Section 143(3)Section 271(1)(c)

salary, income from house property, salary as a working-partner from firm and interest income. Apart from the above, assessee had also shown agricultural income of Rs.20,35,953/-. The AO after scrutiny framed the assessment u/s.143(3) of the Act, wherein, he made an addition of Rs.16 ... which amount was estimated by the AO as agricultural expenses @60% of the gross agricultural income declared as Rs.33,33,843/-, by holding as under:- 5. Assessee has filed a cash book for the agricultural activity which contains date-wise amounts received from sale of agricultural produce, as also

Satyajit Pravinsinh Kumpawat, Gandhinagar vs. The Income Tax Officer, Ward-4, Gandhinagar

In the result, the appeal of the assessee is dismissed

ITA 695/AHD/2024[2020-21]Status: DisposedITAT Ahmedabad02 May 2025AY 2020-21

Bench: Dr. B.R.R. Kumarshri T.R. Senthil Kumar

For Appellant: Shri Parin S. Shah, ARFor Respondent: Shri S.K. Agal, Sr.DR

Section 115BSection 143(3)Section 250Section 68

NFAC, Delhi is grievously erred in determining the disallowance of the balance amount of Rs. 14,33,983/- at the rate of 15% of agriculture income out of the total disallowance of Rs. 28,67,967/- being the estimate of 30% expenses of net agriculture income is quite illegal ... activities and has filed his return of income for the year under consideration on 30.03.2021 determining income of Rs. 9,80,080/- and declaring agricultural income of Rs. 95,59,891/-. The Assessing Officer completed the assessment u/s 143(3) r.w.s. 144B of the Act on 28.09.2022, assessing the income

Stavan Shaileshkumar Rao, Ahmedabad vs. The ITO, Ward-4(2)(3), Ahmedabad

In the result, this claim of the appellant, being insufficiently substantiated, is not acceptable

ITA 358/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad01 May 2025AY 2015-16

Bench: DR. BRR KUMAR (Vice President), SHRI T. R SENTHIL KUMAR (Judicial Member)

Section 68

creditor. In reply the assessee submitted that all 8 parties were involved in agriculture business since many years and have savings out of agriculture income duly earned by them. The Assessing Officer find that assessee could not justify this loan with any documentary evidence about how could these people gather ... Rs.9,62,000/- during the year. ii. The creditors are agriculturists and the sources of loans advanced to the appellant are past savings and agricultural Income earned by them. 7.7 The appellant furnished copies of identity documents, ledger accounts, affidavits and land holding documents of each purported creditor

Uday Karchi, Belagavi vs. Income Tax Officer Ward 4 Belagavi, Belagavi

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

ITA 54/PAN/2025[2017-2018]Status: DisposedITAT Panaji30 Apr 2025AY 2017-2018

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. Nos.54/Pan/2025 (A.Y. 2017-18) Uday Karchi, Vs I.T.O Ward-4, Post.Ainapur,Karchi Gully Civil Hospital Road, . Taluka,Athani, Belgaum-590001. Belgaum-591303, Karnataka. Karnataka. Pan/Gir No. Bewpk2983K (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By None. Revenue By Shri.Sureshkumar C.B.Sr.Dr

scrutiny. The Assessing Officer (AO) based on the information found that the assesse has made cash deposits in the banks and has substantial agricultural income and the notice u/sec142(1) of the Act was issued to furnish the details and sources of investments/ deposits and there was compliance. Whereas ... explanations were called to substantiate the credits in the F.Y.2016-17. And the assessee has filed the details on various dates on the cash deposits, agricultural income and other details. Whereas the A.O was not satisfied with the explanations and dealt on the provisions and made additions u/sec69A

Smt. Kailashben Lavjibhai Daliya, Surat vs. Income Tax Officer, Ward-3(3)(3), Surat

In the result, appeal of the assessee is partly allowed

ITA 367/SRT/2024[2017-18]Status: DisposedITAT Surat30 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.367/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Smt. Kailashben Lavjibhai Daliya, Vs. The Ito, K-701, River View Heights, Pedar Road, Ward – 3(3)(3), Mota Varachha, Surat - 394101 Surat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aiapp7993D (Appellant) (Respondent) Appellant By Shri Ashwin K. Parekh, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 12/02/2025 Date Of Pronouncement 30/04/2025

Section 115BSection 250Section 69A

said amount increased to Rs.25,13,128/- as on 01.04.2015, because the appellant had declared income of Rs.3,71,590/- and agricultural income of Rs.1,47,580/- only in her return of income. The appellant has not submitted the copy of the return for earlier assessment years. Be that

Pinkesh Subhashchandra Patel, Anand vs. The Income Tax Officer, Ward-1(3)(1), Petlad

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

ITA 391/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad30 Apr 2025AY 2017-18

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 391/Ahd/2024 ("नधा"रण वष" / Assessment Year : 2017-18) बनाम/ Pinkesh Subhashchandra The Income Tax Officer Patel Ward-1(3)(1), Petlad Vs. 116, Sardar Chowk, Near Dairy, Tal. Petlad, Bharel, Dist. Anand, Gujarat 388480 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Bgrpp8413J (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Dhrunal Bhatt, Ar. ""यथ" क" ओर से/Respondent By : Shri Prateek Sharma, Sr. Dr 04/02/2025 Date Of Hearing Date Of Pronouncement 30/04/2025 O R D E R The Present Appeal Has Been Filed By The Assessee Against The Order Passed By The Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre (Nfac), Delhi (In Short ‘The Cit(A)’) Under Section 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) Dated 02.02.2024 Pertaining To Assessment Year 2017- 18. 2. The Grounds Raised In The Appeal By The Assessee Are As Under:

For Appellant: Shri Dhrunal Bhatt, ARFor Respondent: Shri Prateek Sharma, Sr. DR

Section 250Section 69A

Appellant's case, the Hon'ble CIT(Appeals) has grossly neglected erred in not appreciating the fact that cash deposited partially out of the agriculture income which was accepted by the same Id. Assessing Officer in earlier assessment proceeding of AY 2016-17. 5. In law and in the facts ... father, Ld. Counsel contended that these savings were attributable to the ITA No. 391/Ahd/2024 [Pinkesh Subhashchandra Patel vs. ITO] A.Y. 2017-18 - 5 – agricultural income on account of the agricultural activity being carried out by his father. 10. He, therefore, contended that the entire source of cash deposit

Mashrubhai Karnaji Rabari, Banaskantha vs. The Income Tax Officer Ward 2, Palanpur

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

ITA 1920/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad30 Apr 2025AY 2017-18

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 115BSection 139(9)Section 142(1)Section 144Section 69A

response, the assessee filed his Return of Income on 04-12-2019 declaring total income of Rs.1,80,930/- and agricultural income of Rs.30,284/-. 3.1 The assessee explained that the cash deposit in bank accounts is nothing but sale of milks to Cooperative Society and also produced bank statements ... statements and other details. Perusal of the same makes it very clear that the deposits were made on account of sale of milks and agricultural income. There is no substantial increase in the cash deposits during demonetization period comparing with the earlier years. Thus

Versibhai Thakor, Patan vs. The Income Tax Officer, Ward-3, Patan

In the result, appeal filed by the assessee is allowed

ITA 1509/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad30 Apr 2025AY 2017-18

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Ms. Astha Maniar, ARFor Respondent: Shri Prateek Sharma, Sr. DR

Section 250Section 69A

Profit and loss Accounts for F.Y. 2016-17 is enclosed herewith for your ready reference. Further Sir I am agriculturist and having Gross Agriculture Income worth Rs. 331471/-. This income was received in cash and deposited in my Bank Accounts. Copy of Agriculture bills are enclosed herewith for your review ... from the above, the assessee had explained the source of cash deposit in the bank account as from his business of Charcoal trading and agricultural income amounting to Rs.4,95,016 /- & Rs.3,31,471/- respectively. The assessee had substantiated the same by furnishing copy of the P&L account

Vtp Foods, Pune vs. ITO Ward 7 (3), Pune

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

ITA 2878/PUN/2024[2017-18]Status: DisposedITAT Pune30 Apr 2025AY 2017-18

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2017-18

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Arvind Desai, Addl CIT DR

Section 143(2)

land used for agriculture purpose. 8. According to the Assessing Officer, the details provided by the assessee do not commensurate with its claim of agricultural income and cash deposits. He therefore, asked the assessee to explain as to why an amount of Rs.50,99,000/- should not be brought ... return of income of the land owners for A.Y 2015-16, 2016-17 & 2017-18 it is seen that they have not shown any agricultural income any of the year. This clearly shows that the land was not under cultivation. Thus you have been failed to establish that the land

V. Venkataraman HUF, Virudhunagar vs. DCIT, Ncc-2, Madurai

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

ITA 431/CHNY/2025[2017-18]Status: DisposedITAT Chennai30 Apr 2025AY 2017-18

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.431/Chny/2025 Assessment Years: 2017-18 V.Venkataraman Huf Deputy Commissioner Of Income Represented By V. Kalavathy, Tax, W/O.Late V.Venkataraman, Non-Corporate Circle-2, No.25, Thillai Nagar, Sattur, Madurai. Virudhunagar Dist, Tamil Nadu-626 203. [Pan: Aachv5604B] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri S.Sundar Raman, Ca. प्रत्यर्थी की ओर से /Revenue By : Ms.Gowthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 23.04.2025 घोषणा की तारीख /Date Of Pronouncement : 30.04.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri S.Sundar Raman, CAFor Respondent: Ms.Gowthami Manivasagam, JCIT

account of unexplained cash deposits in the bank account made during the demonetization period and treatment of Rs. 30,64,903/- as non-agricultural income. At the outset, Ld.Counsel for the assessee submitted that the Ld.CIT(A) has passed an ex-parte order without giving sufficient opportunity of being heard ... Ld.First Appellate Authority while merely dismissing the appeal on grounds of non- compliance. Details placed on records during the present proceedings indicate that agricultural income has been accepted by the Revenue in earlier years. Be that as it may be, we are of the considered view that, considering overall facts

ACIT Circle 2(1), Gwalior vs. Govind P Garg, Morena

In the result, Revenue’s appeal is dismissed

ITA 76/AGR/2017[2009-10]Status: DisposedITAT Agra29 Apr 2025AY 2009-10

Bench: : Smt. Annapurna Gupta & Shri Sunil Kumar Singhassessment Year: 2010-11

Section 132(1)Section 250

submitted his response on 16.12.2011 in respect of the unexplained cash credits of Rs.9,50,201/-, unexplained cash receipts of Rs.5,25,000/-, unexplained agricultural income of Rs.63,990/- and unexplained cash receipts of Rs.1.81 crores from sale of property at Indore. However, learned Assessing Officer observed that the assessee ... Learned Assessing Officer also found that the assessee did neither furnish the Mandi bills nor produced land holding details crop wise in respect of agriculture income of Rs.63,990/- and accordingly assessed total income at Rs.2,02,32,801/-. 3. Assessee preferred an appeal before learned CIT(Appeals) against

Sabirhusen Rasulbhai Malek, Surat vs. ITO, Ward 2(1), Bharuch

In the result, appeal of the assessee is dismissed

ITA 468/SRT/2024[2017-18]Status: DisposedITAT Surat29 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.468/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Sabirhusen Rasulbhai Malek Vs. The Ito, Indian Oil Pump, Devaliya Ward - 2(1), Narmada, Devaliya So - 391121 Bharuch "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aoppm9978Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Kinjal V. Shah, Ca Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 17/02/2025 Date Of Pronouncement 29/04/2025

Section 143(2)Section 250Section 270ASection 69A

brief are that the assessee filed his return of income electronically on 30.10.2017 for AY.2017-18, declaring total income of Rs.2,81,500/- and agricultural income of Rs.8,59,379/-. The case was selected for complete scrutiny under CASS. Various notices u/s 143(2) and 142(1) were issued and served

Clive Richard Butterfield, Lucknow vs. ITO- 3(1), Lucknow-New, Lucknow

In the result, the appeal of the assessee is allowed

ITA 214/LKW/2025[2017-18]Status: DisposedITAT Lucknow29 Apr 2025AY 2017-18

Bench: Shri Anadee Nath Misshra

Section 143(3)Section 69A

income, opening cash, cash flow statement, withdrawals etc. It is not in dispute that the assessee has multiple sources of income (salary, rent, agricultural income, income from other sources). It is also not in dispute that the assessee himself and his wife are senior citizens suffering from medical ailments. Under

Pradeep Wig, New Delhi vs. ACIT Central Circle-5, New Delhi

The appeals of the Revenue are dismissed

ITA 406/DEL/2021[2012-13]Status: DisposedITAT Delhi29 Apr 2025AY 2012-13

Bench: Shri M. Balaganesh & Shri Anubhav Sharma

ready reference reliance is placed on the following judicial precedents as under: MRS. BACHA F. GUZDAR v. CIT (1955) 27 ITR 0001 (SC) Agricultural income—Dividend from tea companies— Assessee, a shareholder in a company engaged in manufacture of tea whose income was exempt to the extent

Sasi Chellan, Trivandrum vs. Assistant Commissioner of Income Tax, Circle 1(2), Thiruvananthapuram

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

ITA 750/COCH/2023[2017-18]Status: DisposedITAT Cochin28 Apr 2025AY 2017-18

Bench: Shri Inturi Rama Rao & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Smt. Leena Lal, Snr. ARFor Respondent: Shri G.Surendranath Rao, CA

Section 56Section 68

year were only from the accumulated savings of agriculture and other incomes. The Ld.AR further submitted that the documents in support of the agricultural income were filed before the Ld.CIT(A), which are all in the vernacular language but unfortunately, the Ld.CIT(A) had refixed the addition made ... time of hearing, before the Ld.CIT(A) had furnished the Page 4 of 6 various documents in support of his contention that the agricultural income earned were brought into the business of the assessee. The Ld.CIT(A) in his order in paragraph number 4.2 had observed that even though

Araguntulu Balaramraja Ram Geetha, Rajapalayam vs. Income Tax Officer, Ward 3, Virudhunagar, Income Tax Office

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

ITA 331/CHNY/2025[2018-2019]Status: DisposedITAT Chennai28 Apr 2025AY 2018-2019

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.:331/Chny/2025 िनधा"रण वष" / Assessment Year: 2018-19 Araguntulu Balaramraja Ram The Income Tax Officer, Geetha, Vs. Ward 3, Income Tax Office, No.141, Viruthunagar, Railway Feeder Road, Palayapalayam, Virudhunagar – 626 001. Dharmaraja Big Street, Rajapalayam- 626 117. [Pan: Banpr-3583-H] (""यथ"/Respondent) (अपीलाथ"/Appellant)

For Appellant: Shri. T.Vasudevan, AdvocateFor Respondent: Shri. Keerthi Narayanan, JCIT

Section 144Section 68

assessment year 2018-19 declaring total income of Rs.7,64,410/-. The case was selected for a limited scrutiny for the reason large agricultural income that large agriculture income. Accordingly, statutory notices were issued to the assessee. However, the assessee did not participate in the assessment proceedings and hence

Sadik Daudbhai Nandoliya, Surat vs. ITO, Ward 2(1), Bharuch

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

ITA 889/SRT/2024[2012-13]Status: DisposedITAT Surat25 Apr 2025AY 2012-13

Bench: Shri Siddhartha Nautiyal & Shri Bijayananda Pruseth

For Appellant: Shri Jigar Adhiyaru, A.RFor Respondent: Shri Mukesh Jain, Sr. DR

Section 143Section 271(1)(b)Section 44ASection 69Section 69A

notice under Section 148 of the Act, the assessee filed return of income declaring total income of Rs. 1,97,885/- including net agricultural income of Rs.1,65,000/-. The Assessing Officer noted that the assessee has claimed that it is engaged in the business of selling milk and vegetables

Jaswinder Singh Legal Heir of Avtar Singh, Patiala vs. PCIT( Central) Ludhiana, Ludhiana

The appeal stand dismissed

ITA 450/CHANDI/2024[2019-20]Status: DisposedITAT Chandigarh25 Apr 2025AY 2019-20

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 450/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2019-20) Shri Jaswinder Singh Pr. Cit (Central) (L/H Of Sh. Avtar Singh) Ludhiana. बनाम/ Vs. Village Prour Bhunerheri, Patiala. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaopr-6348-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ashok Goel (Ca). – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 22-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 25-04-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of This Appeal, The Assessee Assails Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax (Central), Ludhiana-1 (Pr.Cit) For Assessment Year (Ay) 2019-20 Vide Impugned Order Dated 19-03-2024 In The Matter Of An Assessment Framed By Ld. Ao U/S.153C Of The Act On 24-02-2022. Having Heard Rival Submissions, The Appeal Is Disposed-Off As Under. 2. The Assessment Was Framed On The Assessee Pursuant To Search Action On Son Of The Assessee Sh. Jaswinder Singh Rana Wherein

For Appellant: Sh. Ashok Goel (CA). – Ld. ARFor Respondent: Sh. Manav Bansal (CIT) – Ld. DR

Section 153CSection 153DSection 263Section 69C

assessee u/s 263 on the ground that the assessee incurred cash expenditure of Rs.4,81,600/- which was stated to be sourced out of agricultural income. However, there was no withdrawal from the bank. Thus, the source of cash expenditure on behalf of Shri Jaswinder Singh Rana was not examined