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2022 (6) TMI 1234 - ITAT PUNEDisallowance in respect of agricultural expenses - assessee declared gross agricultural receipts - AO found the expenses to be on lower side by considering the general market trend for agricultural expenses being incurred at 35% of gross agricultural income - HELD THAT:- AO has simply rejected the assessee’s claim of agricultural expenses being on the lower side on the basis of a yardstick of 35% being “trend of current year”. It is not understandable as to where from such ‘trend’ came into vogue. If the percentage of agricultural expenses shown by the assessee for the year under consideration is lower than that of the immediately preceding year, it is better than that for the two years immediately prior thereto. Here is a case in which the assessee maintained complete details of agricultural expenses, which have not been faulted with by the AO. If the expenses were inadequate or wanting in any respect, the AO ought to have rejected such expenses by giving some plausible reasons, whereafter, he could have gone ahead with making a best judgment on some rational basis. Having not done so and simply making the addition on the basis of some ‘trend’, we find no reason to sustain the disallowance. For the foregoing reason, we are satisfied that the authorities below were not justified in making and sustaining the addition in such an ad hoc manner. The same is directed to be deleted. - Decided in favour of assessee.
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