Unexplained Cash Credit Addition of ₹1.77 Cr: ITAT Remands Matter for Verification of Agricultural Income and Submitted Evidence [Read Order]
The Tribunal remanded the entire issue back to the Assessing Officer (AO) for a fresh look, noting that the evidence submitted by the assessee was not adequately considered by the lower authorities.
unexplained - cash - credit - taxscan
unexplained - cash - credit - taxscan
The Ahmedabad Bench of the Income Tax Appellate Tribunal Remanded the matter for verification of Agricultural Income and evidence submitted by the assessee in the case involving unexplained cash credit addition of ₹1.77 Crore.
Jigar Patel (assessee) had filed his return for Assessment Year (A.Y.) 2020-21, declaring a total income but claiming a substantial exemption of ₹1,21,19,751 as agricultural income. The assessee case was selected for limited scrutiny due to this large agricultural income claim and large cash deposits relative to the returned income.
The Assessing Officer (AO) proceeded to make a full addition of ₹1,77,16,980 as unexplained cash credit under Section 68 of the Income Tax Act. Aggrieved by the AO’s order, the assessee filed an appeal before the Commissioner of the Income Tax (appeals) [CIT(A)].
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The CIT(A) also confirmed the ₹1.77 Cr addition made by the AO and dismissed the appeal filed by the assessee. Aggrieved by the CIT(A)’s order, the assessee preferred an appeal before the ITAT.
The counsel for the assessee argued that both the AO and the CIT(A) failed to take cognizance of the comprehensive evidence filed by the assessee during the assessment proceedings. This evidence specifically related to the nature of his agricultural income and the supporting receipts.
The two-member bench comprising Suchitra Kamble (Judicial Member) and Narendra Prasad Sinha (Accountant Member) observed the materials on the record and heard the contention of the assessee and the revenue.
The tribunal noted that the materials on record clearly indicated that neither the AO nor the CIT(A) had at all considered the evidences filed by the assessee including that of agricultural income and the receipts given by the assessee while earning the agricultural income.
The tribunal held that the issue required proper verification in light of the submitted evidence and the matter was consequently remanded back to the file of the Assessing Officer with a direction to grant the assessee a fresh opportunity of hearing. In the result, the appeal filed by the assessee was partly allowed for statistical purposes.
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