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Judgment
This assessee’s appeal for Assessment Year: 2020-21, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and Order No. ITBA/NFAC/S/250/2025-26/1085986700(1), dated 13.02.2026 involving proceedings under section 143(3) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as the ‘the Act’).
Heard both the parties. Case file perused.
It emerges at the outset during the course of hearing that the assessee/appellant is aggrieved against the lower authorities’ assessment and lower appellate findings restricting his claim of having derived agricultural income amounting to Rs. 31.50 lakhs to Rs. 4,82,500/- only. This is what forms the sole substantive issue for the tribunal’s apt adjudication in the instant appeal.
I have given my thoughtful consideration to the assesse’s and the Revenue’s respective submissions. Learned counsel more particularly argues that once the assessee had declared an agricultural income of Rs. 4.82 lakhs in the preceding assessment year, both the lower authorities couldn’t have adapted the very figure in the impugned assessment year. When the assessee’s bank account had rather reflected credits of Rs. 17.31 lakhs coming from four nurseries as well as which could not be prima facie treated as unexplained. Be that as it may, it is deemed appropriate in the larger interest of justice that a lump sum addition of Rs. 5 lakhs only in the assessees would be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs. 26,67,500/- in other words. Necessary computation shall follow as per law.
This assessee’s appeal is partly allowed.