“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

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

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

Govdappagouda Channabasangouda Patil, Hubli vs. Income Tax Officer, Ward-3(2), Hubli

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

ITA 1461/BANG/2024[2015-2016]Status: DisposedITAT Bangalore30 May 2025AY 2015-2016

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year :2015-16

For Appellant: Sri Narendra Sharma, A.RFor Respondent: Smt. Neha Sahay, D.R

Section 143(1)Section 143(2)Section 143(3)Section 250Section 41Section 44ASection 68

However, the assessee had only submitted the RTC copies of the agricultural land holdings to the tune of 63 acres in support of his agricultural income. Further, the AO observed that few bills in support of purchase of seeds and sale of agricultural produce were also submitted along with copy ... cash flow statement. As the assessee had not produced the copy of sale bills, purchase bills, pahani, details of cultivation in support of agriculture income, the AO proceeded to estimate income of Rs.50,000/- per acre as net income from agriculture after reducing the expenses towards purchase of seeds

Ajay Kumar, Ghaziabad vs. Pr. CIT (Central), Meerut

In the result, appeal of the assessee is dismissed

ITA 733/DEL/2021[2016-17]Status: DisposedITAT Delhi30 May 2025AY 2016-17

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishra

Section 143(2)Section 143(3)Section 263

assessee submitted replies time to time on ITBA Portal. Details filed by the Assessee are placed on record. 3. The assessee has shown gross agriculture income of Rs. 18,84,000/- and not expenses has been shown. From the balance sheet it is clear that the assessee has not claimed ... expenses in this respect. It is therefore, expenses related to agriculture income is estimated @ 30% i.e. Rs. 5,65,200/- is added to the income of the assessee. Thus net agriculture income is to be computed at Rs. 13,18,800/- instead of Rs. 18,84,000/- for the purpose

Dashrath Kunwar, Jalore vs. ITO, Ward-2, Jalore

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

ITA 32/JODH/2024[2013-14]Status: DisposedITAT Jodhpur29 May 2025AY 2013-14

Bench: BEFOREDR. MITHA LAL MEENA (Accountant Member), SHRI ANIKESH BANERJEE (Judicial Member)

For Appellant: Shri Rajendra Jain, Advocate /For Respondent: Shri Karni Dan, Addl.CIT (Sr.DR.)

Section 143(3)Section 147Section 148Section 250

Raniwada on 31/10/2012. The Ld.AO asked for source for depositing cash in bank account of the assessee and the assessee replied that he had agricultural income and the amount accumulated was deposited in the bank account. In this respect the assessee submitted an affidavit and the documents related to “Khasra

Late Oghadbhai Karabhai Odedra (L/H Babubhai Odedra), Porbandar vs. Income Tax Officer, Ward - 2(4), Porbandar

In the result, appeal filed by the assessee is partly allowed, in above terms

ITA 915/RJT/2024[2010-11]Status: DisposedITAT Rajkot29 May 2025AY 2010-11

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No.915/Rjt/2024 िनधा"रणवष" / Assessment Year: (2010-11) (Hybrid Hearing) Late Oghadbhai Karabhai Odedara Vs. Income Tax Officer, (L/H Babubhai Oghadbhai Odedara) Ward-2(4), At Bavalvav, Porbandar, Porbandar Gujarat-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aajpo3410B (Appellant) (Respondent) Appellant By : Shri Dushyant Maharshi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. (Dr) Date Of Hearing : 05/ 03/2025 Date Of Pronouncement : 29/05/2025 आदेश / O R D E R Dr. Arjun Lal Saini, Am

For Appellant: Shri Dushyant Maharshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. (DR)

Section 127(1)Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 69A

income of the assessee u/s 69A of the I.T. Act. 4. During the assessment proceedings, the assessing officer also noticed that assessee had shown agricultural income, amounting to Rs. 3,59,000/-. In response to notice, under section 142(1) of the Act, the assessee submitted its reply before ... assessing officer that this is purely an agricultural income derived from agricultural activities and disclosed the same in the return of income. However, the assessing officer rejected the above contention of the assessee and observed that during the course of assessment proceedings, the assessee has not submitted the copy

Kundanben Maheshchandra Gor, Umbergaon vs. Income Tax Officer, Vapi

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

ITA 728/SRT/2024[2015-16]Status: DisposedITAT Surat29 May 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.728/Srt/2024 Assessment Year: (2015-16) (Hybrid Hearing) Kundanben Maheshchandra Gor, Vs. The Ito, Plot No 1502, 3Rd Phase, Ward-5, Gidc, Umbergaon - 396195 Vapi "थायीलेखासं./जीआइआरसं./Pan/Gir No: Awkpg6190P (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Chetan Khakhkhar, Ar Respondent By Shri Mukesh Jain, Sr. Dr Date Of Hearing 20/03/2025 Date Of Pronouncement 29/05/2025

Section 10Section 143(2)Section 250Section 56(2)(vii)

circumstances of the case as well as in law on the subject, the learned CIT A has erred in confirming the disallowance of agricultural income amounting to Rs. 23,65,220/-.” “2. On the facts and circumstances of the case as well as in law on the subject, the learned ... selected for scrutiny under CASS and notices were issued u/s 143(2) and 142(1) of the Act. The assessee had not shown any agricultural income in the preceding assessment year 2014-15, but has shown net agricultural income of Rs.24,12,200/- in the subject AY. The case

DCIT-CC-2(1), Ahmedabad vs. Vedprakash Devkinandan Chiripal, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 617/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad29 May 2025AY 2017-18

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Rignesh Das, CIT-DRFor Respondent: Shri Vartik Chokshi , AR

Section 63

that, • The assessee purchased agricultural lands registered in his name. This proves that the assessee is an agriculturist though he has not earned any agricultural income in earlier years. • The land at the time of purchase was agricultural in nature as per the land records. • The Sale Deeds submitted

Mr. Ananda Kondu Akhade, Pune vs. ITO Ward 9(5), Pune

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

ITA 31/PUN/2025[2012-13]Status: DisposedITAT Pune29 May 2025AY 2012-13

Bench: Shri Manish Borad & Ms. Astha Chandra

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Madhan Thirmanpalli

facts and circumstances prevailing in the case and as per provisions and scheme of the Act it be held that the addition of Agricultural income of Rs. 49,520/- so made as income from other sources by Ld. AO and that upheld by Ld. CIT(A)-NFAC is incorrect. Accordingly ... unexplained investment and also rejected the explanation about income of current year and accumulated funds. The Ld.AO also did not accept the agriculture income of Rs.49,520/- and made an addition of the same as income from other sources. The Ld. AO therefore completed the reassessment at assessed income

Parasmal Ravindra Kumar, Chennai vs. ITO Non Corp Ward 10(5), Chennai

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

ITA 2859/CHNY/2024[2016-17]Status: DisposedITAT Chennai29 May 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunatha

For Appellant: Shri D. Anand, Advocate

Section 2(14)

assessee is an individual and filed his return of income on 29.09.2016 declaring an income of %.8,87,330/-. The assessee also reported agricultural income of %.1,21,450/-. The case was selected for complete scrutiny. The assessee is a financier and is also derives income from salary, house property ... dated 14.09.2015 and submits that the disputed lands are classified as agricultural lands in the Revenue Records. Further, he submits that the earning of agricultural income is not 4 LTA. No.2859/Chiny/24 a statutorily prescribed condition to determine the character of the land. The Id. AR challenged that the lower authorities

Balubhai Kikabhai Patel, Valsad vs. Principal Commisioner of Income Tax, Valsad

In the result, appeal of the assessee is allowed

ITA 461/SRT/2024[2018-19]Status: DisposedITAT Surat28 May 2025AY 2018-19

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.461/Srt/2024 Assessment Year: (2018-19) (Physical Court Hearing) Balubhhai Kikabhai Patel Principal Commissioner Of बनाम/ Nahuli, Karmbele, Umbergon, Income-Tax, Valsad, Room No. Vs. Surat-396 105 301, 3Rd Floor, Palak Arcade, Shanti Nagar, Tithal Road, Valsad-396 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Akqpp 2563 H (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Rasesh Shah, Ca राज" की ओर से /Respondent By Shri Ritesh Misra, Cit-Dr सुनवाई की तारीख/Date Of Hearing 13/03/2025 उद्घोषणा की तारीख/Date Of Pronouncement 28/05/2025

Section 143(2)Section 143(3)Section 263Section 263(1)Section 68

declaring total income at Nil and exempt income of Rs.38,68,230/-. The case was selected for limited scrutiny on the issue of agricultural income. In response to the notices u/s 143(2) and 142(1) of the Act, assessee submitted various details. The assessee had shown gross agricultural receipts ... after claiming expenses of Rs.23,36,222/-, he had shown net agricultural income of Rs.33,81,983/-. After considering submission of the assessee, AO issued a show cause notice along with draft assessment order proposing disallowance of agricultural income of Rs.13,07,563/- because assessee has no documents except self

Gurkartar Singh S/O Tarsem Singh, Patiala vs. Income Tax Officer, Ward Nabha

In the result, Assessee’s appeal is allowed

ITA 1002/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh28 May 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1002/Chd/2024 "नधा"रण वष" / Assessment Year : 2018-19 Gurkartar Singh, Ito, बनाम S/O Tarsem Singh, National E- Dharoki, Thuhi Assessment Vs. Nabha, Patiala 147201 Centre, Nabha "थायी लेखा सं./Pan No: Ifyps9189K अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Ms. Anjali Bansal, Advocate राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 10.03.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 28.05.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 27.08.2024 Of Ld. Commissioner Of Income Tax(Appeals), National Faceless Appeal Centre, Delhi For A.Y. 2018-19. 2. Grounds Of Appeal Are As Under: -

For Appellant: Ms. Anjali Bansal, AdvocateFor Respondent: Sh. Vivek Vardhan, Addl. CIT, Sr.DR

Section 10(1)Section 115BSection 142(1)Section 143(2)Section 69A

Income tax (Appeals), National Faceless Appeal Centre, Delhi is illegal, unjust and uncalled for. 2. That the claim of exemption withdrawn on account of agriculture income u/s 10(1) and added back to return income u/s 69A worth Rs. 32,07,300/- and confirmed by the CIT, National Faceless Appeal ... Centre is illegal, unjust and uncalled for. 3. That the withdrawal of exemption claimed u/s 10(1) on account of agricultural income by the Income Tax Officer, National E- assessment Centre and added back in the income of the assessee u/s 69A of the Income Tax Act,. 1961 and confirmed

Syam Keshav Kulkarni, Aurangabad vs. Income Tax Officer, Ward-1 (1), Aurangabad

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

ITA 792/PUN/2024[2012-13]Status: PendingITAT Pune28 May 2025AY 2012-13

Bench: SHRI MANISH BORAD (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Ramesh Thete (Virtual)For Respondent: Shri Aviyogi Ambadkar

Section 133(6)Section 144Section 147Section 148Section 2(14)Section 69A

relief towards agricultural income/savings can be given to the extent of Rs.1,00,000/- even though the appellant had not given any proof of agricultural income received or returned in any of the earlier years. Thus, maximum the appellant can get relief of is Rs.8.20,000/-. The addition made ... them were owned by the assessee, he deleted the addition of Rs.7,20,000/- and also accepted the savings of Rs.1 lakh out of agricultural income of earlier years, & accordingly allowed the benefit of Rs.8,20,000/- and confirmed the addition of Rs.12,57,000/- in the hands

Arumugam Malinguprabhu, Mettupalayam vs. ITO, Non Corporate Ward 3(1), Coimbatore

Appeal of the assessee is partly allowed

ITA 2946/CHNY/2024[2018-19]Status: DisposedITAT Chennai28 May 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

For Appellant: Mr. Girish Kumar AdvocateFor Respondent: Mrs.Samantha Mullamudi, Addl

Section 115B

agriculturist and is not doing any activities other than agricultural activities and has been filing return of income for all the assessment years offering agricultural income. During the assessment year under consideration, the appellant filed his return of income offering agricultural income of Rs.56,08,750/-. The assessee also reported ... interest income at Rs.14,566/. The case of the assessee was selected for scrutiny to verify the issue of "Large agricultural income compared to total income" and in this regard, the assessee was issued notices regarding the agricultural income earned, for which the assessee had filed detailed submissions establishing

Sandeep Kumar Ravindra Murthy Kunduguli, Chickmaglur vs. The Assistant Commissioner of Income Tax, Hassan

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

ITA 236/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 May 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2017-18

For Appellant: Shri Adarsh S Shenoy, C.AFor Respondent: Shri Subramanian S, JCIT (DR)

assessee is against the action of the ld. CIT(A) in confirming the addition of ₹11,00,000 by reclassifying the declared agricultural income as non-agricultural income. Page 2 of 4 3. The AO, during the assessment proceedings, noted that the assessee had shown agricultural income of ₹11 lakhs ... appeal, the ld. CIT(A) held that submission of landholding details alone does not establish that agricultural operations were carried out or that agricultural income was earned. The ld. CIT(A) observed that the assessee had failed to produce details regarding the crops cultivated, sale invoices, confirmations from purchasers

Mukesh Bansal HUF Through Its Karta Mukesh Bansal, Delhi vs. ITO, Ward-34(4), Delhi

ITA 4349/DEL/2024[2018-19]Status: DisposedITAT Delhi28 May 2025AY 2018-19

Bench: Shri Shamim Yahya & Shri Sudhir Kumar

For Appellant: Sh. Yogesh Harjai, CA & Sh. Siddarth Malhotra, AdvFor Respondent: Sh. Dheeraj Kumar Jain, Sr. DR

Section 10(1)Section 10BSection 143(1)Section 154

declaring total income at Rs.4,86,820/- which includes the business income as well as interest income. Apart from above, the assessee also earned agricultural income and during the previous year earned total income of Rs.20,48,631/- which included net profit from agricultural income of Rs.16 ... Gross receipts from agriculture Rs.55,06,542/- less expense incurred on agricultural income Rs.38,76,884/-. The assessee while filing its ITR, claimed the said income as exempt income in Schedule-BP and accordingly reduced the same from the total income. The assessee also added back to income, the expenses

Nadeem Ahmad Khan, Dehradun vs. DCIT, Dehradun

In the result, both appeals of the assessee are allowed as above

ITA 16/DDN/2024[2017-18]Status: DisposedITAT Dehradun27 May 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 142(1)Section 270ASection 271DSection 273BSection 274

notice under section 142(1) of the Act, filed his Income Tax Return (ITR) on 27.06.2019 declaring taxable income of Rs.5,80,800/- & agricultural income of Rs.3,14,500/-. The consequential assessment was completed at income of Rs.10,55,110/- During the relevant year, the assessee had received land compensation

Nadeen Ahmad Khan, Dehradun vs. DCIT, Dehradun

In the result, both appeals of the assessee are allowed as above

ITA 15/DDN/2024[2017-18]Status: DisposedITAT Dehradun27 May 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 142(1)Section 270ASection 271DSection 273BSection 274

Shri Vakeel Singh S/O.Sh.Chhota Singh, Mansa vs. Income Tax Officer Ward-1(4), Mansa

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

ITA 634/ASR/2024[2022-23]Status: DisposedITAT Amritsar27 May 2025AY 2022-23

Bench: Sh. Udayan Dasgupta & Sh. Brajesh Kumar Singh

For Appellant: Sh. J. K. Gupta, Adv

Section 142(1)Section 143(2)Section 144Section 249(3)Section 250

circumstances of the case and in law, the CA filed the return of income of assessee wrongly by mentioning figures of agricultural income of some other assessee. The assessee was unaware of wrong figures filed by CA. So, the mistake of CA cannot be basis of addition in case ... case are that the assessee is an agriculturist and has filed return of income declaring total income at Rs.2,54,690/- (plus agricultural income of Rs.1.62 cores). In course of assessment proceedings, there has not been any response from the assessee to various notices issued

Mohan Lal Yadav, Ajitgarh vs. Income Tax Officer, Ward-2, Sikar

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

ITA 162/JPR/2025[2017-18]Status: DisposedITAT Jaipur27 May 2025AY 2017-18

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vedant Agarwal, CA (Thru: VC)For Respondent: Shri Gautam Singh Choudhary, Addl. CIT-DR

Section 115BSection 131Section 142(1)Section 143(2)Section 69A

case and in law also Ld. Lower authoritiesgrossly erred in not considering the fact that on what basis Ld A.O. admitted the agriculture income of Rs. 10,00,000/- as against of Rs. 5,48,903/- declared in original return or of Rs. 21,52,000/- declared in the revised ... case, LD. Lower authoritiesgrossly erred in not considering the size of agricultural land available with the assessee and the fact that no agricultural income was declare in last two years. 8. Alternatively, the appeal order is passed without giving opportunity of personal hearing despite request. Such order is against

Kalubhai Maghabhai Bharvad Through Legal Heir Takhuben Bharvad, Anand vs. The ITO, Ward-1(3)(1), Petlad

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

ITA 2061/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad26 May 2025AY 2011-12

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Adjournment Application Filed (Sr. DR)

Section 147Section 69A

side. 4. The brief facts of the case are that the assessee filed return of income declaring total income of ₹1,48,990/- and agricultural income of ₹8,95,100/-. As per information available with the Income Tax Department, the assessee had made cash deposits of over ₹10 lakh ... time and was undergoing treatment. The assessee also filed sale bills towards sale of rice (agricultural produce) to demonstrate that the assessee was earning agricultural income, which were duly disclosed by the assessee in its return of income, for the impugned year under consideration. On going through the facts

D. Selvakumar (HUF), Namakkal vs. ITO, Ward-2, Namakkal

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

ITA 357/CHNY/2025[2016-17]Status: DisposedITAT Chennai26 May 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Respondent: Mr.Keerthi Narayanan, JCIT

during assessment proceedings; and the Ld.CIT(A) noted that in the absence of proper explanation with supporting evidences with respect to the claim of agricultural income of Rs.25,13,960/-, he concluded that the AO has rightly made addition under the head “income from other sources”. Therefore, according ... Karta of HUF and it had filed its RoI for AY 2016-17 on 15.07.2016 declaring total income at Rs.2,48,620/- and agricultural income of Rs.25,13,960/- which RoI was selected for scrutiny; and the AO issued six (6) notices but the assessee failed to reply. Therefore