ITAT Upholds Rs. 49.55 Lakh Addition For Bogus Agricultural Income Claim
The Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, has upheld the addition of ₹49,55,101 to the taxable income of an assessee, Jigar Patel, treating the amount as unexplained cash credit under Section 68 of the Income Tax Act, 1961.
The bench of B.R.R. Kumar (Vice-President) and T.R. Senthil Kumar (Judicial Member) has affirmed the findings of the lower authorities, concluding that the explanation of increased income due to reduced costs lacked merit. The tribunal found the claim “unreasonable, illogical and unacceptable,” especially in light of natural calamities that year.
The case pertains to the assessment year 2018–19, during which the assessee had declared total income of ₹5.48 lakh and agricultural income of ₹75.54 lakh. The return was selected for scrutiny based on the abnormally high agricultural income.
Upon examination, the Assessing Officer (AO) noted that the claimed agricultural income had tripled from the previous year’s figure of ₹25.99 lakh, despite Gujarat witnessing severe floods in 2017. The AO found the sudden rise “unbelievable and concocted,” citing lack of documentary evidence and inconsistencies in the explanation provided by the assessee.
The Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), upheld the AO’s findings, emphasizing that the taxpayer failed to provide credible details such as crop types, sales records, and justifications for the reduction in agricultural expenses.
The ITAT dismissed the appeal filed by Jigar Patel and confirmed the addition of ₹49.55 lakh as income from unexplained sources.
Case Details
Case Title: Jigar Patel Versus ITO
Case No.: I.T.A. No.604/Ahd/2025
Date: 26.06.2025
Counsel For Appellant: None
Counsel For Respondent: B.P Srivastava, Sr DR
Mariya is the Senior Editor at JurisHour. She has 5+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started as a freelance tax reporter in the leading online legal news companies like LiveLaw & Taxscan.
