Best judgment agricultural income assessment sustained where prescribed records were not produced and field inspection supported the estimates.

Where an assessee failed to produce prescribed books and supporting material to substantiate agricultural yield, the authority could reject the EB-2 register and adopt a best judgment assessment based on average yield of earlier seasons, acreage, climatic conditions and surrounding facts; the coffee income addition was therefore sustained. On pepper vines, an estate inspection disclosed 2,000 vines, and the assessee did not dislodge that factual basis; the estimate, moderated for disease-affected vines, was held reasonable. The revision petition accordingly failed and both additions were left undisturbed.

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Issues: (i) Whether the addition made towards coffee income by rejecting the EB-2 register and adopting the average yield of previous seasons was justified. (ii) Whether the estimation of income from pepper vines was sustainable on the facts and evidence available.

Issue (i): Whether the addition made towards coffee income by rejecting the EB-2 register and adopting the average yield of previous seasons was justified.

Analysis: The assessee relied only on the EB-2 register, but did not produce the prescribed books of account or supporting material to substantiate the declared yield. Under Rule 9-A of the Karnataka Agricultural Income Tax Rules, 1957, the method of accounting and supporting records had to reflect the yield and corresponding expenditure. In the absence of cross-verifiable accounts, the Assessing Officer was entitled to adopt a best judgment approach, taking into account the average yield of earlier seasons, acreage, climatic conditions and the surrounding factual circumstances. The appellate authorities and the Tribunal accepted that factual assessment.

Conclusion: The addition towards coffee income was rightly sustained, against the assessee.

Issue (ii): Whether the estimation of income from pepper vines was sustainable on the facts and evidence available.

Analysis: The inspection of the estate disclosed 2,000 pepper vines, and the Managing Partner of the assessee was present when the relevant information was gathered. The assessee did not place material to dislodge the factual basis for treating the vines as yielding during the relevant period. The estimate was not treated as a mere guess; it was based on on-site information and a moderated allowance for disease-affected vines. On that factual foundation, the estimate of pepper income was held to be reasonable.

Conclusion: The estimation of pepper income was rightly sustained, against the assessee.

Final Conclusion: The revision petition failed, and the orders sustaining both additions were left undisturbed.

Ratio Decidendi: Where the assessee does not maintain and produce the prescribed accounts to substantiate agricultural yield, the authority may sustain a best judgment assessment based on objective surrounding circumstances and relevant field inspection material.

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