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Income-tax addition under section 69A fails where agricultural income was supported by land records, produce bills and bank entries

Current Tax Online · (2026) 1 CTOTTJ 1973 (Ahd)

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PARSHOTMBHAI PATEL vs. INCOME TAX OFFICE

5-Second Takeaway

The addition under section 69A for unexplained agricultural income was deleted because the assessee had filed land extracts, produce and trading bills, and bank statements showing the related credit entries. The court noted that the revenue had accepted the assessee’s agricultural income in earlier years, and a revised computation alone could not justify disallowance.


The dispute concerned an addition made under section 69A on the footing that the assessee’s agricultural income was unexplained. The assessee relied on documentary material including land extracts, bills relating to agricultural produce and trading, and bank statements showing the relevant credit entries.

The assessing officer disregarded those materials and proceeded to treat the amount as unexplained income. The record, however, showed that the assessee’s agricultural income had been accepted by the department in earlier years and that the income claimed for the year under consideration arose from the same agricultural activity.

The decision holds that a revised computation by itself was not a proper basis to reject the agricultural income claim. In the face of the supporting records, the section 69A addition could not be sustained.

The result was deletion of the addition treated as unexplained agricultural income.

Source & Citation

CasePARSHOTMBHAI PATEL vs. INCOME TAX OFFICE

CourtITAT, AHMEDABAD 'SMC' BENCH

Date18th June, 2026

Current Tax Online report(2026) 1 CTOTTJ 1973 (Ahd)

Sections consideredIncome-tax Act, 1961, s. 69A

ResultIn favour of : Assessee

Suggested citationPARSHOTMBHAI PATEL vs. INCOME TAX OFFICE, (2026) 1 CTOTTJ 1973 (Ahd)

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Published by Current Tax Online. Source and citation information, where available, is preserved with the Case Law.

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