2020 (1) TMI 830 - HC - Income Tax

Deductions relating to, operating expenses, the cash deposit in bank and agricultural income - HELD THAT - Revenue followed due process of law to its hilt and in spite of granting the assessee several opportunities, he miserably failed to comply with the notices issued by the concerned authorities. As such, the assessment was completed in the manner as stated in the order reproduced hereinabove. Assessee did not submit evidence or material at all before the lower Income Tax authorities in support of its claims for the deductions relating to, operating expenses, the cash deposit in bank and agricultural income. Decided in favour of the Revenue

Summary

Issues:
1. Whether the ITAT was legally correct in its view that the assessee did not submit evidence or material before the lower Income Tax authorities in support of its claims for deductions.
2. Whether ITAT was justified in dismissing the assessee's appeal regarding operating expenses, agricultural income, and cash deposit in bank accounts.

Detailed Analysis:

Issue 1:
The case involved an appeal under section 260 of the Income Tax Act, 1961, admitted by an earlier Division Bench of the High Court. The questions raised pertained to the submission of evidence by the assessee before the lower authorities to support deductions claimed. The assessment order highlighted that despite multiple notices and opportunities given to the assessee, compliance was not met. The Revenue completed the assessment based on the information available. The Commissioner of Income Tax (Appeals)-I also noted the lack of evidence provided by the assessee to support claimed deductions. The Income Tax Appellate Tribunal, Agra Bench, found that the additional evidence submitted post-assessment did not serve the purpose and upheld the Commissioner's order. The Tribunal concluded that the assessee failed to explain the operating expenses, cash deposit in the bank, and agricultural income with supporting evidence.

Issue 2:
Regarding the second issue, the Commissioner of Income Tax (Appeals)-I dismissed the grounds raised by the assessee related to deductions for operating expenses, agricultural income, and cash deposit in the bank. The Income Tax Appellate Tribunal, Agra Bench, concurred with the Commissioner's findings, stating that the assessee could not provide evidence for the claimed expenses and income. The Tribunal rejected the grievances raised by the assessee, emphasizing the lack of merit in the claims. Ultimately, the High Court upheld the Tribunal's decision, stating that the Tribunal was legally and judicially justified in its findings based on the materials presented. The judgment favored the Revenue, and the appeal was disposed of accordingly.

In conclusion, the High Court upheld the decision of the Income Tax Appellate Tribunal, Agra Bench, regarding the lack of evidence provided by the assessee to support claimed deductions for operating expenses, agricultural income, and cash deposit in bank accounts. The judgment emphasized the importance of substantiating claims with proper evidence in income tax proceedings.