“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

Income Tax Officer, Raisen vs. Late Sudha Agrawal Th. L/H Manmohan Agrawal, Raisen

Appeal is dismissed and assessee’s cross-

ITA 281/IND/2023[2016-17]Status: DisposedITAT Indore06 Jun 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniincome-Tax Officer, Late Smt. Sudha Agrawal, बनाम/ Raisen (L/H: Manmohan Agrawal) Vs. 19/1, Shreeji Enterprise, Near Sbi, Sagar Road, Yashwant Nagar, M.P. (Pan: Abfpa4355G) (Revenue/Appellant) (Assessee/Respondent)

Section 142(1)Section 143(2)Section 143(3)Section 159Section 54F

Late Smt. Sudha Agarwal’ filed her return of AY 2016-17 on 12.09.2016 declaring a total income of Rs. 7,89,800/- (with an agricultural income of Rs. 1,06,052/-). The case of assessee was selected for scrutiny-assessment vide notice dated 04.07.2017 u/s 143(2). Ultimately

Sh. Arvind Singh Chauhan, Jaipur vs. DCIT, Circle-7, Jaipur

Appeal is disposed of

ITA 291/JPR/2024[2014-15]Status: DisposedITAT Jaipur05 Jun 2024AY 2014-15

Bench: Ld. Cit(A), Notices Are Stated To Have Been Issued By The Said

For Appellant: Sh. P. C. Parwal, CAFor Respondent: Sh. A. S. Nehra, Addl. CIT

Section 143(3)Section 250Section 271

assessee had filed his return of income on 08.09.2015 declaring total income of Rs. 1,36,27,850. He also declared his agricultural income as Rs. 9,54,948/-. However, the department selected his case for scrutiny. Thereupon, notices came to be issued to the assessee. He participated

Satya, Shimla vs. ITO, Ward-2, Shimla

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

ITA 531/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh03 Jun 2024AY 2015-16

Bench: SHRI A.D.JAIN (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Vishal Mohan, Sr. Advocate with Shri Aditya Sood, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr.DR

Section 143(3)Section 282(1)Section 56(2)(vii)

that the assessee filed her return of income, for the year under consideration, declaring a total taxable income of Rs.2,25,590/- apart from agricultural income of Rs.53,465/-. The case of the assessee was selected for scrutiny within the meaning of Section 143(3) of the Income

Praful Raghuveer Chandawarkar, Pune vs. Income Tax Officer, Circle-7, Pune

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

ITA 187/PUN/2024[2017-18]Status: DisposedITAT Pune03 Jun 2024AY 2017-18

Bench: Shri Inturi Rama Rao & Ms. Astha Chandraआयकर अपील सं. / Ita No.187/Pun/2024 "नधा"रण वष" Assessment Year : 2017-18

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Sourabh Nayak

Section 143Section 143(1)Section 143(2)

accommodation. The Return of Income for the A.Y.2017- 18 was filed on 16.03.2018 declaring total income of Rs.70,95,240/- which is inclusive of agricultural income of Rs.4,08,000/-. The return was processed vide intimation order dated 08.03.2019 u/s.143(1) of the Act making an addition of Rs.5 ... that there was tax deduction of source in respect of the lease rent received from the agricultural land which was claimed to be an agricultural income by the appellant. 4. Being aggrieved by the said intimation, an appeal was filed before the CIT(A) who vide impugned order partly allowed

Deputy Commissioner of Inome Tax, Central Circle-2(1), Hyderabad vs. Nama Seetaiah, Hyderabad

In the result, appeals filed by the assessee for the A

ITA 454/HYD/2021[2011-12]Status: DisposedITAT Hyderabad03 Jun 2024AY 2011-12

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha, G.आ.अपी.सं /Ita Nos.1523/Hyd/2019 & 393/Hyd/2021 (िनधा"रण वष"/Assessment Year: 2010-11 & 2011-12) Shri Nama Seetaiah Vs. Dy. C. I. T. Hyderabad Central Circle 3(2) Pan:Aaupn8501F Hyderabad (Appellant) (Respondent) आ.अपी.सं /Ita No.454/Hyd/2021 (िनधा"रण वष"/Assessment Year: 2011-12) Dy. C. I. T. Vs. Shri Nama Seetaiah Central Circle 2(1) Hyderabad Hyderabad Pan:Aaupn8501F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Murali Mohan Rao, Ca राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 14/05/2024 घोषणा की तारीख/Pronouncement: 03/06/2024 आदेश/Order Per Manjunatha, G. A.M These Cross Appeals Filed By The Assessee, As Well As The Revenue Are Directed Against, The Separate But Identical Orders Of The Learned Cit (A) 12 Hyderabad Even Dated 22.08.2019

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR

Section 132

Page 26 of 30 ITA Nos 1523 393 454 Nama Seetaiah of Rs.55,80,500 as salary income from Madhucon Projects Ltd and also agricultural income of Rs.66,12,720/-. Further, the appellant is also deriving interest and dividend to the tune of Rs.17.00 lakhs. Therefore, the learned

Nama Seetaiah, Hyderabad vs. Deputy Commissioner of Income Tax, Central Circle-3(2), Hyderabad

In the result, appeals filed by the assessee for the A

ITA 393/HYD/2021[2011-12]Status: DisposedITAT Hyderabad03 Jun 2024AY 2011-12

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR

Section 132

Nama Seetaiah, Hyderabad vs. Dy. Commissioner of Income Tax, Central Circle-3, Hyderabad

In the result, appeals filed by the assessee for the A

ITA 1523/HYD/2019[2010-11]Status: DisposedITAT Hyderabad03 Jun 2024AY 2010-11

For Appellant: Shri P Murali Mohan Rao, CAFor Respondent: : Shri Shakeer Ahmed, DR

Section 132

Indira Ramaiah, Bangalore vs. Income Tax Officer, Ward-1(2)(1), Bangalore

In the result, the appeal of the assessee is dismissed

ITA 507/BANG/2024[2015-16]Status: DisposedITAT Bangalore03 Jun 2024AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2015-16

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Ms. Shamala D.D., Addl.CIT(DR)(ITAT), Bengaluru

Section 115BSection 148Section 234ASection 56(2)Section 69

have PAN which is duly reported in Form 26AS by Titan Co. Ltd. Payment was made in cash by Puttarangaiah out of his agricultural income and savings. She submitted confirmation of Mr. P. Venkatachalaiah S/o. Puttarangaiah is filed in this regard, since Mr. Puttarangaiah expired. 8. In respect of purchase ... course of assessment proceedings the assessee did not substantiate the credential of the buyer and not submitted any single document in support of agricultural income of the buyer. Therefore it cannot be said that jewellery was purchased by other person. Further in respect of joint purchase of property, Srinivasan Mahesh

Ketan Harilal Mehta HUF by Its Karta Ketan H Mehta, Mumbai vs. ITO Ward-33(2)(2) Mumbai Presently Juridiction With ITO 42(1)(1) Mumbai, Mumbai

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

ITA 770/MUM/2023[2014-15]Status: DisposedITAT Mumbai03 Jun 2024AY 2014-15

Bench: Shri B R Baskaran & Shri Pavan Kumar Gadaleketan Harilal Mehta Huf Vs. Ito-42(1)(1), (By Its Karta Kautilya Bhavan, Ketanmehta)No.B/1101, Bkc,Bandra(E), Siddhi Vinayak Tower, Mumbai-400051. Opp Phoenix Hospital, Chikuwadi, Mumbai-400092. Pan/Gir No. : Aaehk3266N Appellant .. Respondent Appellant By : Shri. Nishit Gandhi.Ar Respondent By : Shri. P.D. Chougule.Sr.Dr Date Of Hearing 02.04.2024 Date Of Pronouncement 03.06.2024 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac)(Cit(A)) Delhi Passed U/Sec 143(3) & U/Sec250 Of The Income Tax Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. Nishit Gandhi.ARFor Respondent: Shri. P.D. Chougule.Sr.DR

Section 10(38)Section 68Section 69C

books maintained by the Assessee. The ITAT has recorded a finding that the source of funds for acquisition of the shares was the agricultural income which was duly offered and assessed to tax in those Assessment Years. The Assessee has produced certificates from the aforesaid four companies to the effect

Vivek Prahladbhai Patel, Vadodara vs. The Income Tax Officer, Ward-4(1)(10), Vadodara

The appeal of the assessee is allowed

ITA 370/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad31 May 2024AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2017-18 Vivek Prahladbhai Patel The Income Tax Officer, B-302, Balaji Greens, Vs Ward-4(1)(10), B/H Sitaram Complex, Chhani- Vadodara Canal, Vadodara-391740 Gujarat Pan: Babpp7859 N अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Jigar Adhyaru, Ca Revenue By : Shri N.J. Vyas, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 16/05/2024 घोषणा क" तार"ख /Date Of Pronouncement: 31/05/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthis Appeal By The Assessee Is Directed Against The Order Of The Additional/Joint Commissioner Of Income Tax (Appeals)-1 Visakapatnam (Hereinafter Referred As “Cit(A)”), Dated 5-1-2024, For The Assessment Year2017-18, Whereby The Cit(A) Upheld The Addition Made By The Assessing Officer (Hereinafter Referred As “Ao”) Under Section 69A Of The Income Tax Act, 1961 (Hereinafter Referred As “The Act”). Vivek Prahladbhai Patel Vs. Ito Asst. Year : 2017-18

For Appellant: Shri Jigar Adhyaru, CAFor Respondent: Shri N.J. Vyas, Sr.DR

Section 69A

assessee under section 69A of the Act. 3. The assessee contended that the said cash deposits were from the accumulated savings and agricultural income of his parents. Rs.2,13,000/- were given by assessee’s father Shri Pralhadbhai Kantilal Patel and Rs.2,15,000/- by assessee’s mother Smt. Govadvariben ... should have been considered in a judicious manner. 11. Ld. Departmental Representative, on the other hand, stated that there is no any proof of agricultural income. However, neither AO nor CIT(A) have asked assessee to produce any proof for the agricultural income of father. 12. Therefore, in the interest

Subhash Sadashiv Sathe, Pune vs. Income Tax Officer, ITO Ward 14(4), Pune

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

ITA 745/PUN/2024[2017-18]Status: DisposedITAT Pune31 May 2024AY 2017-18

Bench: Shri Inturi Rama Rao & Ms. Astha Chandraआयकर अपील सं. / Ita No.745/Pun/2024 "नधा"रण वष" Assessment Year : 2017-18

For Appellant: NoneFor Respondent: Shri R.Y. Balawade

Section 143(3)

passed u/s.143(3) at a total income of Rs.13,52,050/-. While doing so, the AO made addition of Rs.10,24,811/- disbelieving the agricultural income for the failure of assessee to substantiate the agricultural income. 3. Being aggrieved, an appeal was filed before the CIT(A)/NFAC who vide

Bhuramal Tanted, Sailana, Ratlam vs. Income Tax Officer -2, Ratlam

In the result the appeal of the assessee is allowed for

ITA 559/IND/2023[2017-18]Status: DisposedITAT Indore31 May 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 144Section 250

Ld.AO have erred in not appreciating that the assessee is a Kisan (Agriculturist) and cash has been deposited out of accumulated and agriculture income of the assessee who was aged 93 years during the relevant Assessment Year 2017-18 and residing in rural area. Thus, the addition of Rs.17 ... assessee filed the submissions before Ld. CIT(A) along with supporting evidences comprising of land holding record of the assessee to show the agriculture income as source of deposits in the bank account. Apart from the land holding and revenue record the bank account statements were also 2 Bhuramal Tanted

Rajendra Sharma, Ujjain vs. CIT (A), Ujjain

Appeal is allowed for statistical purpose

ITA 375/IND/2023[2016-17]Status: DisposedITAT Indore31 May 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2016-17 Rajendra Sharma, Ito, A-25/12, Vasant Vihar, Ward-2(3), बनाम/ Indore Road, Ujjain Ujjain Vs. (Assessee/Appellant) (Revenue/Respondent) Pan: Ahcps4766Q Assessee By Shri Ashish Goyal & Shri Nd Patwa, Ars Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 30.05.2024 Date Of Pronouncement 31.05.2024

Section 143(3)

filed return declaring a total income of Rs. 4,04,750/- and Page 1 of 11 Rajendra Sharma ITA No. 375/Ind/2023 – AY 2016-17 agricultural income of Rs. 6,40,000/-. The return was selected under CASS for “Limited scrutiny” to verify “Large cash deposit in savings bank account ... Ultimately, the AO passed assessment-order u/s 143(3) after determining total income at Rs. 43,85,710/- and agricultural income at Rs. 2,00,000/-. Aggrieved, the assessee filed appeal to CIT(A) and partly succeeded. Still aggrieved, the assessee has come in next appeal before us. 3. Originally

Arunachalam Srinivasan, Perambalur vs. ACIT, Central Circle-1, Trichy

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

ITA 1607/CHNY/2023[2014-15]Status: DisposedITAT Chennai31 May 2024AY 2014-15

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

For Appellant: Shri G. Baskar, Advocate &For Respondent: Shri V. Nandakumar, CIT

Section 132Section 153C

tribunal has found that with regard to cash and jewellery, the explanation of the assessee was that he had agricultural properties and derived agricultural income. That income was utilised to acquire jewellery that was belonging to him and his family. With regard to cash and stated to be recovered from

Assistant Commissioner of Income Tax, Central Circle-1, Trichy vs. A. Srinivasan, Perambalur

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

ITA 1527/CHNY/2023[2014-15]Status: DisposedITAT Chennai31 May 2024AY 2014-15

For Appellant: Shri G. Baskar, Advocate &For Respondent: Shri V. Nandakumar, CIT

Section 132Section 153C

Prabhu Dayal, New Delhi vs. ITO Ward - 45(1), New Delhi

In the result, the appeal is allowed for statistical purposes

ITA 381/DEL/2020[2011-12]Status: DisposedITAT Delhi31 May 2024AY 2011-12

Bench: Shri G.S. Pannu, Vice- & Shri Anubhav Sharmaassessment Year: 2011-12 Prabhu Dayal, Vs. Income Tax Officer, M-156, Raghubir Nagar, Ward 45(1), New Delhi-1100 37 New Delhi Pan :Afepd3762K (Appellant) (Respondent)

Section 147Section 148

book; submissions filed before the AO in remand proceedings, available at page 25; proportion of land ownership of the assessee through which he earned agricultural income, available at page 47 of the paper book; confirmations from the person who took assessee’s land on Batia (tenancy) and paid rent, available

Harichandrasinh Dharmendrasinh Zala, Bhavnagar vs. ITO, W-1(2), Bhavnagar

The appeal of the assessee is allowed for statistical purposes

ITA 1115/AHD/2023[2011-2012]Status: DisposedITAT Ahmedabad30 May 2024AY 2011-2012

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar, Accountnat Member Assessment Year : 2011-12 Harichandrasinh Income Tax Officer Dharmendrasinh Zala Vs Ward-1(2), 524-C, Kaliyabid, Bhavnagar, Bhavnagar Gujarat-364002 Pan: Aaipz1959K अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri M.K. Patel, Ar Revenue By : Shri N.J. Vyas, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 16/05/2024 घोषणा क" तार"ख /Date Of Pronouncement: 30/05/2024 आदेश/O R D E R Per Makarand V. Mahadeokarthis Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals) – National Faceless Appeal Centre (Nfac) (Hereinafter Referred As “Cit(A)”] Dated 30.10.2023 For The Assessment Year 2011-12, Wherein The Cit(A) Partially Confirmed The Addition Made By The Assessing Officer (Hereinafter Referred As “Ao”) Under Section 144 Of The Income Tax Act, 1961(Hereinafter Referred To As “The Act”).

For Appellant: Shri M.K. Patel, ARFor Respondent: Shri N.J. Vyas, Sr.DR

Section 142(1)Section 144Section 148Section 68

considered the additional evidence filed by the assessee, including the profit and loss account, 7/12 extracts, and bank passbook, which supported the claim of agricultural income. The CIT(A) after seeking remand report from the AO granted partial relief by excluding the amount related to the receipt from the sale ... compliance by the assessee during the assessment stage. The CIT(A) has given partial relief based on the evidence relating to agricultural income. 8. In the interest of justice and to provide a fair opportunity to the assessee, we deem it appropriate to set aside the order

Venkata Narayana Gaddam, Nalgonda vs. Income Tax Officer, Ward-1, Nalgonda

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

ITA 478/HYD/2024[2017-18]Status: DisposedITAT Hyderabad30 May 2024AY 2017-18

Bench: Shri Laliet Kumarआ.अपी.सं /Ita No.478/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Venkata Narayana Vs. Income Tax Officer Gaddam, Nalgonda Ward-1 Pan:Afbpg8798K Nagonda (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 30/05/2024 घोषणा की तारीख/Pronouncement: 30/05/2024 आदेश/Order

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: : Shri Shakeer Ahmed, DR

Section 142(1)Section 144Section 69A

appeal before the Tribunal. 5. The learned Counsel for the assessee submitted that the remaining Rs.7,50,000/- earned by the assessee from agricultural income and from advocate profession. Thus, the learned Counsel for the assessee prayed for remanding the issue to the file of the learned CIT (A) NFAC

Shaily Prince Goyal, Mumbai vs. Income Tax Officer-27(3)(1), Navi Mumbai

In the result, the appeal of the assessee Shri Yogesh Popatlal Thakkar in ITA No

ITA 4271/MUM/2023[2013-14]Status: DisposedITAT Mumbai30 May 2024AY 2013-14

For Appellant: Dr. K Shivaram Sr. Advocate & Shashi BekalFor Respondent: Ms. Sujatha Iyangar SR AR

Section 10(38)Section 143(3)Section 148Section 250Section 68Section 69C

Rks Vijayakumar, Coimbatore vs. ITO, Delhi

In the result the appeal is allowed

ITA 655/CHNY/2024[2018-19]Status: DisposedITAT Chennai29 May 2024AY 2018-19

Bench: Shri Aby T. Varkey, Jm & Shri Amitabh Shuklaआयकर अपील सं./Ita No.655/Chny/2024 निर्धारण वर्ा /Assessment Year: 2018-19. Rks Vijayakumar Income Tax Officer, Kovilpalayam Road, Vs. Che-W-(63) (95) Negamam, Pollachi, Chennai Coimbatore-642001 [Pan-Agdpv5035H)

For Appellant: Shri Anand Babunath, F.C.AFor Respondent: Shri P.Sajit Kumar, JCIT

total non–compliance on the part of the assesse. Perusal of the assessment order dated 26.02.2021 shows that the AO had made addition treating agricultural income as income from other sources in view of the fact that the assesse failed to file satisfactory supporting documentary evidences. The assesse had argued ... that it is doing agricultural activity for the last several years and its agricultural income has been assessed accordingly. A proper adjudication of the case by the Appellate Commissioner can only happen once the assesse complies fully and correctly with its notices. We are of the view that ends