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Judgment
This assessee’s appeal for Assessment Year 2021-22 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1085295663(1) dated 29.01.2026, in proceedings u/s 143(3) of the Income Tax Act, 1961 (in shor t “the Act”).
Heard both the p arties at length. Case file perused.
Coming to the assessee’s sole substantive ground raised herein, it emerges during the course of hearing that both the learned lower author ities have treated cash credits/deposits in his bank account amounting to Rs.36,88,549/- as unexplained; in assessme nt order dated 21.12.2022 as upheld in the lower appellate discussion.
It is in this factual backdrop that the learned counsel has filed a list o f the asse ssee’ s 25 “J” for ms issue d on vario us occasions by the concerned trading agency regarding purchase of his agricultural produce totaling to Rs.32,98,28 7/- which not only carry presumption of correctness under the state agricultural mar keting law but also conclusive that he had infact cultivated and so ld the crops in issue. The facts also remains that the assessee appears not to have got all the facts reconciled and verified to the entire satisfaction of both the learned lo wer authorities. It is thus deemed appropriate in the larger interest of justice that a lump sum addition of Rs.2 ,00,000/- only in his hands w ould be just and proper with a rider that the same shall not be treated as a precedent. The assessee gets relief of Rs.34,88,549/- in other words.
This assessee’s appeal is partly allowed.