ITAT restores onion-sale agricultural income claim for fresh verification under section 69A

5-Second Takeaway

The tribunal restored the assessee’s claim of agricultural income from onion cultivation for fresh adjudication, giving one more opportunity to substantiate the alleged receipts of Rs. 30,18,910. It noted that the assessee was an agriculturist and had earned agricultural income, but the lower authorities had found no evidence of cultivation खर्च and had relied on RTC entries showing nil onion crop.

The assessee claimed that Rs. 30,18,910 received from onion sales was agricultural income and therefore not liable to addition as income from undisclosed sources under section 69A. The assessing officer and the Commissioner (Appeals) rejected the claim, chiefly because no supporting evidence was produced for the expenditure said to have been incurred on the onion crop.

The record also contained RTC details noting a nil onion crop during the relevant year. At the same time, there was no dispute that the assessee was an agriculturist and had earned agricultural income during the year under consideration.

On that basis, the tribunal considered it appropriate to grant the assessee one more opportunity to substantiate the claim. It therefore restored the matter to the jurisdictional assessing officer for de novo adjudication after considering the evidence on record.

The result was a remand, with the claim left open to be examined afresh on the available material.