ITAT: Agricultural Income Claim Rejected for Lack of Evidence

ITAT Pune upheld the addition as unexplained income, dismissing the assessee’s appeal after the assessee failed to produce any evidence to substantiate her agricultural income claim from just 0.11 acres of land.

The present appeal has been filed by Lata Nivrutti Hake (Appellant) against ITO (Respondent) in the Income Tax Appellate Tribunal (ITAT) Pune Bench “A”, before Shri R.K. Panda (Vice President) and Ms Astha Chandra (Judicial Member). The case is related to the assessment year 2017-18 and was decided on December 12, 2025. The appeal is filed against the order dated January 3, 2025, passed by the CIT(A).

The assessee filed his return of income on December 28, 2017, declaring a total income of Rs 139,270. The case was selected for investigation, and a notice under section 143(2) of the Income Tax Act, 1961, was also issued to the assessee asking him to provide the required details and documents. However, the assessee did not respond to any of these notices. As a result, AO rejected his claim of agricultural income and treated it as “unexplained income” and made an addition of Rs. 78,70,685 to his taxable income.

The assessee files an appeal before the CIT(A). The CIT(A) added that the appellant is running a nursery and owns only 0.11 acres of land. Based on this land ownership, it is highly doubtful to generate a gross agricultural produce worth Rs 78,70,685. During the appeal, the CIT(A) asked the Assessing Officer to give a remand report. However, the assessee did not file any reply or objections to this remand report. Because of this non-response, the CIT(A)/NFAC accepted the Assessing Officer’s version and decided the matter against the assessee.

Assessee, being aggrieved with the CIT(A) decision, approached the ITAT. The Tribunal heard the DR and examined all the records. It was clear that the assessee did not submit any documents or evidence to the Assessing Officer to prove the claim of agricultural income. Because of this, the AO treated the amount of Rs 78,70,685 as unexplained income and added it to taxable income. When the matter went to appeal, the CIT(A) agreed with the Assessing Officer’s decision. Even during the appeal proceedings and before the Tribunal, the assessee failed to submit any supporting material. Since no evidence was produced at any stage, the Tribunal found no mistake in the order of the CIT(A)/NFAC and therefore confirmed the addition and dismissed the assessee’s appeal.