ITAT Remits Rs.49.55 Lakh Agricultural Income Addition to CIT(A) :

The appeal was filed by Jigar Patel against the order of the NFAC dated March 4, 2025, arising from assessment proceedings under Section 143(3) of the Income Tax Act for Assessment Year 2018-19. The assessee had filed his return of income on July 31, 2018, declaring total income of Rs.5,48,790. The case was selected for scrutiny to examine agricultural income of Rs.75,54,378 disclosed during the relevant year.

The AO was not convinced with the agricultural income claimed, particularly since the assessee had disclosed agricultural income of only Rs.25,99,275 in the preceding assessment year. Accordingly, the AO treated Rs.49,55,101 as bogus agricultural income and made an addition under Section 68 of the Act. The assessment under Section 143(3) was completed on March 18, 2021, determining total income at Rs.55,03,891. Aggrieved, the assessee approached the CIT(A), but the appeal was dismissed. 

Before the Tribunal, the assessee submitted that no compliance could be made before the CIT(A) and that it had dismissed the appeal without adjudicating the grounds on merits. Accordingly, the assessee sought another opportunity of being heard and requested that the matter be restored to the CIT(A). The Revenue, on the other hand, supported the CIT(A)'s order. The Tribunal observed that the assessee had not provided any cogent reason for his non-compliance before the CIT(A). It specifically noted that as many as six opportunities had been granted by the CIT(A), but the assessee failed to comply on every occasion.

Nevertheless, considering the circumstances, the Tribunal deemed it appropriate to impose a cost of Rs.10,000, payable to the Prime Minister National Relief Fund within 15 days from receipt of the order. Subject to payment of the cost, the Tribunal set aside the matter to the file of the CIT(A) and directed the authority to provide one more opportunity to the assessee to make submissions concerning the grounds raised before it.