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“agricultural income”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(1A) / Rule 7, 7A, 7B(1), 7B(1A), 82,868 judgments

The decision most relied on for agricultural income is CIT v. Ghanshyam (HUF) (315 ITR 1), cited in 363 judgments on BharatTax.

Leading authorities on agricultural income

CIT v. Ghanshyam (HUF)
315 ITR 1 · 2009 · Supreme Court
363
citing judgments

Interest received under Section 28 of the Land Acquisition Act, 1894, is considered part of the enhanced compensation on compulsory acquisition of land. It is taxable as 'capital gains' and not separately as 'interest income' under the head Income from Other Sources.

CIT v. Punjab State Cooperative Agricultural Development Bank Ltd.
389 ITR 68 · 2016 · High Court
192
citing judgments

Income earned by a cooperative society from investing its surplus funds in short-term deposits and securities is not attributable to its core activities and therefore not eligible for deduction under Section 80P(2)(a)(i) of the Income-tax Act.

Mavilayi Service Co-operative Bank Ltd. v. CIT
414 ITR 67 · 2019 · High Court
190
citing judgments

The Full Bench of the Kerala High Court held that a co-operative bank or society is not entitled to a deduction under Section 80P(2)(a)(i) of the Income-tax Act if it provides loans to non-members. This decision was subsequently overruled by the Supreme Court.

Smt. Harshila Chordia v. ITO
298 ITR 349 · 2008 · High Court
187
citing judgments

Cash receipts from customers against genuine delivery of goods or services cannot be added as unexplained cash credits under Section 68. The case also provides guidance on non-disallowance under Section 40A(3) for business payments made in specific contexts like agricultural markets.

Kerala State Co-operative Agricultural and Rural Development Bank Ltd. v. Assessing Officer
154 Taxmann.com 305 · 2023 · Supreme Court
136
citing judgments

Section 80P(4) is not applicable to a cooperative bank unless it is classified as a 'bank' under the provisions of the Banking Regulation Act, 1949. For cooperative banks not meeting this definition, the deduction for interest earned from investments in cooperative societies is available under Section 80P(2)(d) of the Income-tax Act.

CIT v. Raja Benoy Kumar Sahas Roy
32 ITR 466 · 1957 · Supreme Court
132
citing judgments

Income is considered agricultural income, exempt under Section 10(1), only if the land undergoes a measure of cultivation involving basic primary operations prior to germination and subsequent post-germination activities requiring human skill and labour.

Sabarkhanta Zilla Kharid Vechan Sangh Ltd. v. ClT
203 ITR 1027 · 1993 · Supreme Court
98
citing judgments

Co-operative societies or banks engaged in both agricultural and non-agricultural activities are entitled to deduction under Section 80P of the Income Tax Act, 1961, limited only to the profits derived from agricultural activities, not 100% of their gross profits.

CIT v. Usha Stud Agricultural Farms Ltd.
301 ITR 384 · 2008 · High Court
98
citing judgments

An addition cannot be made under Section 68 for cash credits if it is established that the credits do not pertain to the impugned assessment year but relate to earlier assessment years.

Judgments citing agricultural income

Anbhao Parkash S/O Darshan Lal, Village Veere Wala Kalan, Faridkot vs. Income Tax Officer, Ward-3(4), Faridkot, Jurisdictional Assessing Officer, ITO Ward 1, Faridkaot

In the result, the appeal filed by the assessee is allowed

ITA 630/ASR/2024[2012-2013]Status: DisposedITAT Amritsar30 Jun 2025AY 2012-2013

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. Sudhir Sehgal, A.R
Section 142(1)Section 143(2)Section 144Section 148Section 250oSection 69

Cash Deposit Amount received on the basis of Agreement to sell (PB 1. 11.05.2011 10,00,000/- Page 18-22) ll.05.2011 1,25,000/- Agricultural Income 2. 3. 25.08.2011 1,00,000/- Agricultural Income 4. 27.08.2011 1,00,000/- From cash withdrawn on 24.05.2011 Bank Statement on Page ... Agricultural Income J-form attached Pg.29-33 6. 12,03.2012 1,00,000/- Agricultural Income J-form attached Pg.29-33 7. 19.03.2012 50,000/- Agricultural Income J-form attached Pg.29-33 10. A written submission filed by the assessee is also reproduced as under: Regarding the addition of 10 lakhs it is submitted

Income Tax Officer Ward-2 (2), Muktsar vs. Ajaib Singh, Village Bharu

In the result, the appeal of the revenue is dismissed

ITA 354/ASR/2024[2012]Status: DisposedITAT Amritsar30 Jun 2025

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay(Hybrid Hearing) I.T.A. No. 354/Asr/2024 Assessment Year: 2012-13

Section 143(3)Section 2(14)(iii)Section 250Section 54B

deleted the addition by holding as follows: “3. The Assessee is an individual and is an agriculturist. The Assessee and his family are earning agricultural income from their ancestral agricultural land. During the previous year relevant for the A.Y. 2012-13 the Assessee had sold agricultural land measuring 23 Kanai ... obtaining approval of PCIT issued a notice u/s 148. In response to the notice the Assessee filed Return of Income on 27.04.2019 declaring agricultural income of Rs.1,92,580/- and nil taxable income. 3.1 The Assessing Officer on scrutinising the sale deeds of the land sold by the Assessee noted

Dilipsinnh Gambhirsnh Jadeja, Rajkot vs. Income Tax Officer Ward 2(1)(1), Rajkot

In the result, the appeal of the appellant is dismissed

ITA 303/RJT/2024[2017-2018]Status: DisposedITAT Rajkot30 Jun 2025AY 2017-2018
For Appellant: Shri Chetan Agarwal, Ld. ARFor Respondent: Shri K. L. Solanki, Ld. Sr. DR
Section 144Section 144oSection 234ASection 250Section 271ASection 69A

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN

Jivrajbhai Mavjibhai Pa vs. Iya, Suratvs.Income Tax Officer Ward 3(3)(1) Surat, Ayakar Bhawan, Surat

In the result, appeal of the assessee is allowed for statistical purposes

ITA 1102/SRT/2024[2017-18]Status: DisposedITAT Surat30 Jun 2025AY 2017-18

Bench: Shri Tr Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1120/Srt/2024 Assessment Year: (2017-18) (Hybrid Hearing) Jivrajbhai Mavjibhai Pavsiya 204, Amizara Palace, B/H Vs. Gabani Kidney Hospital, Lal Darwaja, Surat-395006 Income Tax Officer Ward No.3(3)(2), Surat, Ayakar Bhawan, Majura Gate Nr. New Civil Hospital, Surat-395 001 स्थायीलेखासं. / जीआइआरसं./Pan/Gir No: Adwpp 2625 F (अपीलार्थी/Appellant) (प्रत्यर्थी / Respondent) निर्धारिती की ओर से /Appellant By Shri Kamlesh Pandya, Ca राजस्व की ओर से /Respondent By Ms. Neerja Sharma, Sr-Dr सुनवाई की तारीख/Date Of Hearing 08/05/2025 उ‌द्घोषणा की तारीख/Date Of Pronouncement 30/06/2025 आदेश / Order Per Bijayananda Pruseth, Am: This Appeal By The Assessee Emanates From The Order Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, 'The Act') Dated 30.08.2024 By The National Faceless Appeal Centre, Delhi /Commissioner Of Income-Tax (Appeals) [In Short, 'Cit(A)'] For The Assessment Year (Ay) 2017-18, Which In Turn Arises Out Of Assessment Order Passed By Assessing Officer (In Short, 'Ao') U/S 143(3) Of The Act Dated 27.12.2019. Grounds Of Appeal Raised By The Assessee Are As Under: "1. Learned Cit(A) Erred In Making Order By Upholding Addition Made By Ito Without Considering Facts, Circumstances Of Our Case & Submission Made By Us During Appeal Proceedings Even Though Source Of Cash Deposit Already Explained, Therefore Section 69A Not Applicable In Our Case.

Section 115BSection 143(2)Section 143(3)Section 250Section 44ASection 69A

also find that in the assessment order u/s 143(3) dated 29.01.2016, the assessee had declared total income of Rs.7,56,050/- and agricultural income of Rs.10,38,320/- (page-96 of PB). The AO has determined total income at Rs.7,71,930/-. Thus, agricultural income of Rs.10 ... been accepted by the AO. In AY 2014-15, assessee had declared gross total income of Rs.3,72,237/- and agricultural income of Rs.3,28,560/- (page-101 of PB). In AY 2015-16, assessee has shown gross total income of Rs.4,90,135/- and agricultural income of Rs.4

Arun Bose, Idukki vs. Income Tax Officer, Thodupuzha

In the result, the appeal filed by the as stands allowed

ITA 381/COCH/2025[2020-21]Status: DisposedITAT Cochin30 Jun 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2020-21 Arun Bose .......... Appellant Pulparambil House, Rajakumari Aruvilanchal P.O., Idukki 685619 [Pan: Bdppp4937G] Vs. The Income Tax Officer, Ward 1 & Tps .......... Respondent Mahima Towers, Temple Road, Thodupuzha Appellant By: Shri Mathew Joseph, Ca Respondent By: Shri Suresh Sivanandan, Cit-Dr Date Of Hearing: 04.06.2025 Date Of Pronouncement: 30.06.2025

For Appellant: Shri Mathew Joseph, CAFor Respondent: Shri Suresh Sivanandan, CIT-DR
Section 115BSection 143(3)Section 263Section 69ASection 69C

order is erroneous and prejudicial to the interests of Revenue for the reason that the AO made addition of Rs. 50,01,695/- disbelieving agricultural income instead of gross receipt of Rs. 76,58,500/- and should have been taxed the same u/s. 69A r.w.s. 115BBE ... considering the submissions made by the appellant, the ld. Pr. CIT had proceeded to hold that since the appellant had failed to substantiate the agricultural income, the entire gross receipts of Rs. 78,58,500/- should be added back as unexplained income and invoked section 115BBE

Ram Singh, District Kaithal, Haryana vs. Income Tax Officer, Ward-1, Kaithal, Income Tax Office, Ambala Road

The appeal of the assessee is dismissed

ITA 920/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh30 Jun 2025AY 2012-13

Bench: The Appeal Is Finally Heard Or Disposed Of.

For Appellant: Shri Nikhil Goyal, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(1)Section 143(3)Section 147Section 148Section 234ASection 69

assessee had duly filed a cash flow statement explaining sources of cash deposits. The cash deposits were out of earlier year’s withdrawals, agricultural income, and loans and advances from family and friends. The assessee is residing in a rural area and is engaged in traditional agricultural and allied activities ... assessee failed to correlate specific withdrawals with specific deposits and had not furnished documentary evidence to prove the genuineness of loans or the agricultural income claimed. Therefore, the AO rightly invoked Section 69 for unexplained money. It was submitted that No evidence for "bayana" from the developer (e.g., MOU, receipt

Ashokbhai Muljibhai Vaniya, Ahmedabad vs. The ITO, Ward-3(2)(1), Ahmedabad

In the result, the appeal of the assessee is partly allowed

ITA 154/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2012-13

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaassessment Year: 2012-13

Section 119(2)(b)Section 144Section 147Section 148

assessment proceeding the assessee could not satisfactorily explain the source of cash deposits. It was contended that the cash deposits were out of agricultural income of the assessee as well as the family members but no evidence in support thereof was filed. Therefore, the AO had treated the entire cash ... erred in confirming addition of Rs.24,43,889/- on account of cash deposit without considering that these deposits represent cash receipts from agricultural income. 4. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in confirming addition

Venkatesh Kammari, Chevella vs. ITO., Ward-1, Vikarabad

In the result, appeal of the assessee is allowed for statistical purposes

ITA 465/HYD/2025[2019-20]Status: DisposedITAT Hyderabad30 Jun 2025AY 2019-20

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA K P BinduFor Respondent: Shri Waseem UR Rehman, Sr. AR
Section 142(1)Section 144Section 144(1)Section 147Section 148Section 148A

year relevant to the assessment year 2019-2020. The assessee has also furnished Form of Declaration to be filed by a person who has agricultural income and is not in receipt of any other income chargeable to income tax in respect of transactions specified in Rule 114B of the Income ... Rules, 1962. In the Form the assessee has shown agricultural income of Rs.3,65,000/-. Therefore, the assessment has been reopened and notice u/sec.148 of the Income Tax Act, 1961 [in short “the Act”] was issued after duly complying with the relevant procedure provided u/sec.148A(d) of the Income

Income Tax Officer, Ward-7(2)(1), Bengaluru, Bangalore vs. M/S. Bangalore Credit Co-Operative Society Limited, Bangalore

ITA 2348/BANG/2024[2020-21]Status: DisposedITAT Bangalore30 Jun 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Smt. Neha Sahay, D.R
Section 250

issued on 22.09.2019. The case was selected under CASS for the following reasons: a. Low Income (including exempt income and agricultural income) in comparison to high loans/advances/investment in shares appearing in balance sheet. ITA Nos.2347 & 2348/Bang/2024 & CO Nos.4 & 5/Bang/2025 M/s. Bangalore Credit Co-operative Society Ltd., Bangalore Page

Mr Manish Jagdish Bajaj, Mumbai vs. PCIT-41, Mumbai

In the result, the appeal of the assessee is allowed

ITA 2758/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Jun 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2020-21 Mr. Manish Jagdish Bajaj Pcit-41, Mumbai Flat No. 605,606, 6Th Floor, Farm Room No. 541, Kautilya Manor Chs Adarsh Colony, Marve Vs. Bhava, C-41 To C-43, G Block, Road, Malad (West), Bandra Kurla Complex, Mumbai- 400064 Bandra (East), Mumbai- 400051 Pan No. Aghpb 6661 P Appellant Respondent

For Appellant: Mr. R A Dhyani, CIT-DRFor Respondent: Mr. Suchek Anchaliya
Section 143Section 143(3)Section 263

return of income . The return of income filed by the by the assessee was selected for limited scrutiny on the issue of agriculture income and selected for limited scrutiny on the issue of agriculture income and selected for limited scrutiny on the issue of agriculture income and credit of brought ... view that after examination he was of the view that assessing officer did not examine did not examine the issue of agricul issue of agricultural income and omission has resulted in under and omission has resulted in under-assessment of income. assessment of income. Accordingly, the Ld. PCIT issued notice

Technoblast Mining Corporation, Raigarh vs. Principal Commissioner of Income Tax, Raipur-1, Raipur

In the result, appeal of the assessee is dismissed

ITA 307/RPR/2025[2020-21]Status: DisposedITAT Raipur27 Jun 2025AY 2020-21

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.307/Rpr/2025 "नधा"रण वष" / Assessment Year : 2020-21 Technoblast Mining Corporation 19, 2Nd Floor, Krishna Complex, Chaityana Nagar, Raigarh (C.G.)- 496 001 Pan: Aaeft5992Q

For Appellant: Shri Rakesh Kumar, AdvocateFor Respondent: Shri Ram Tiwari, Sr. DR
Section 143(3)Section 2(24)(x)Section 263Section 36(1)(va)

Assessing Officer. Thus, there was no material to support the claim of the appellant that the said amount represented compensation for loss of agricultural income. He accepted the entry in the statement of the account filed by the appellant in the absence of any supporting material and without making

Alnesh Akil Somji, Pune vs. Assistant Commissioner of Income Tax, Pune

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 35/PUN/2025[2019-20]Status: DisposedITAT Pune27 Jun 2025AY 2019-20

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Nitin RanderFor Respondent: Shri Amol Khairnar CIT-DR
Section 132Section 139(1)Section 143(2)Section 153ASection 24

proper perspectives. 3. On the facts and circumstances of the case the learned Commissioner of Income Tax (Appeals) has erred in treating Agricultural income of Rs.95,841/- as taxable Income without appreciating the facts of the case in the proper perspectives. 4. On the facts and circumstances of the case ... No.35/PUN/2025 is also allowed. 28. Ground No.3 raised by the assessee relates to the order of the Ld. CIT(A) in treating agricultural income of Rs.95,841/- as taxable income. 29. After hearing both sides, we find the Assessing Officer in the instant case disallowed the claim of agricultural income

Alnesh Mohamadakil Somji, Pune vs. Assistant Commissioner of Income Tax, Pune

ITA 34/PUN/2025[2018-19]Status: DisposedITAT Pune27 Jun 2025AY 2018-19

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Nitin RanderFor Respondent: Shri Amol Khairnar CIT-DR
Section 132Section 139(1)Section 143(2)Section 14ASection 153ASection 24

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND MS ASTHA

Ganapathy Panneerselvam, Chennai vs. The Income Tax Officer, Non Corp. Ward 19(4), Chennai

In the result, the appeal filed by the assessee is allowed

ITA 609/CHNY/2025[2017-18]Status: DisposedITAT Chennai27 Jun 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:609/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Ganapathy Panneerselvam, The Income Tax Officer, Old No.19, New No.49, Vs. Non-Corp. Ward -19(4), Chetty Street, Chennai. Saidapet West, Chennai – 600 015. [Pan:Bikpp-3640-L ] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. R. Venkata Raman, C.A. & Shri. R. S. Lakshmi Narayana, Advocate ""थ" की ओर से/Respondent By : Ms. Sita Krishnamoorthy, J.C.I.T.

For Appellant: Shri. R. Venkata Raman, C.A. &For Respondent: Ms. Sita Krishnamoorthy, J.C.I.T
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 69

from her savings account. She is an agriculturist and she had agricultural income. Once she demonstrated that she was in possession of ₹.7,00,000/- cash plus agricultural income on her hands, if after 40 days, a cash deposit is made to the extent of about ₹.5,20,000/- towards

Bhagirathi Enterprise, Vile Parle West Mumbai vs. Income Tax Officer Ward 34(1)(1), Bandra East Mumbai

In the result, the appeal filed by the assessee for the AY

ITA 3130/MUM/2025[2023-24]Status: DisposedITAT Mumbai27 Jun 2025AY 2023-24

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: Shri Anant N. Pai, CAFor Respondent: Shri Leyaqat Ali Aafaqui
Section 143Section 143(1)Section 154Section 167BSection 2

subject to the provisions of sub-sections (2) and (3). Sub section (2) of section 2 speaks of an assessee having net agricultural income exceeding five thousand rupees, in addition to total income, hence, is not relevant for our purpose. However, sub section (3) of section 2 of Finance

Bhagirathi Enterprise, Vile Parle West Mumbai vs. Income Tax Officer, Ward 34(1)(1), Mumbai Bandra East

In the result, the appeal filed by the assessee for the AY

ITA 3129/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Jun 2025AY 2022-23

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: Shri Anant N. Pai, CAFor Respondent: Shri Leyaqat Ali Aafaqui
Section 143Section 143(1)Section 154Section 167BSection 2

subject to the provisions of sub-sections (2) and (3). Sub section (2) of section 2 speaks of an assessee having net agricultural income exceeding five thousand rupees, in addition to total income, hence, is not relevant for our purpose. However, sub section (3) of section 2 of Finance

Bhagirathi Enterprise, Vile Parle West Mumbai vs. ITO Ward 34(1)(1), Bandra East Mumbai

ITA 3128/MUM/2025[2021-22]Status: DisposedITAT Mumbai27 Jun 2025AY 2021-22

Bench: Shri Vikram Singh Yadav & Ms. Kavitha Rajagopal

For Appellant: Shri Anant N. Pai, CAFor Respondent: Shri Leyaqat Ali Aafaqui
Section 143Section 143(1)Section 154Section 167BSection 2

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “B” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND MS. KAVITHA

Ramesh Mohanlal Zaveri, Mumbai vs. National Faceless Appeals Centre, Delhi

ITA 2428/MUM/2025[2017-2018]Status: DisposedITAT Mumbai27 Jun 2025AY 2017-2018

Bench: Shri Rahul Chaudhary (Jm) & Shri Omkareshwar Chidara (Am) Ramesh Mohanlal Zaveri Ito Ward 26(2)(5) 7/226, Ram Nivas, Sion East Mumbai Mumbai-400 022. Vs. Pan : Aaapz1305K Appellant Respondent

For Appellant: Shri Asif KarmaliFor Respondent: Ms. Sanyogita Kamble
Section 69A

Omkareshwar Chidara (AM) :- The only issue to be decided in the above captioned appeal is whether claim of agricultural income of the appellant is correct or not. In the grounds of appeal, the appellant states that he has got sale and purchase register of agricultural products grown and sold. Sale ... proceeds of this agricultural income were deposited in the bank account during demonetization period and hence the same cannot be doubted by the Revenue. 2. From the assessment order, it is observed that the Ld. AO posted the case for hearing and sought for certain details like copy of audited

Mr. Chengalraya Naidu Rajanbabu, Chennai vs. ITO, Corp. Ward.3(1), Chennai

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1171/CHNY/2025[2017-18]Status: DisposedITAT Chennai26 Jun 2025AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.1171/Chny/2025 िनधा9रण वष9 /Assessment Year: 2017-18

For Appellant: NoneFor Respondent: Shri Vijay Kumar, JCIT
Section 143(3)

Income-tax Act, 1961 (“the Act”), the Assessing Officer made an addition of Rs. 19,25,000/- by treating the agricultural income declared by the assessee as “income from other sources.” Aggrieved by the said addition, the assessee preferred an appeal before the Ld. CIT(A), who confirmed the addition

Rahul Prakash Sankh L/R of Late Prakash Basappa Sankh, Bijapur vs. Income Tax Officer, Ward-1, Bijapur

In the result, the appeal filed by the assessee is allowed

ITA 2370/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 Jun 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2017-18

For Appellant: Smt. Prathiba R, Advocate
Section 142(1)Section 144Section 263Section 69A

this appeal, the total addition made by the AO is about Rs. 6,31,000/- being the income received by way of agricultural income and also income earned through the agriculturists for identifying the borewell points. Admittedly, the assessee also died and only the legal heirs are before ... have also perused the acknowledgement dated 28/04/2023 in which the assessee had attached the agricultural income proof and letters from persons for having paid the honorarium and the death certificate of the assessee. From the said attachments, we understand that the legal heir of the assessee had tried to explain