Best-judgment agricultural income assessment upheld where gross receipts were reasonably apportioned between agricultural and non-agricultural operations.

Assessment on a best-judgment basis under Rule 7, where the assessee failed to furnish complete particulars, was upheld because apportioning gross receipts between agricultural and non-agricultural operations was a reasonable method in the circumstances. The Court found the approach neither perverse nor legally unsustainable, and held that the mere availability of an alternative apportionment method, such as one based on net income, did not by itself justify interference with the assessment order.

---

---

Issues: Whether the assessment made by the Agricultural Income-tax Officer by apportioning gross receipts between agricultural and non-agricultural operations under Rule 7 of the Karnataka Agricultural Income-tax Rules required interference.

Analysis: The assessment was made on a best judgment basis after the assessee did not furnish all relevant particulars. The adopted method of apportioning gross receipts was held to be a reasonable approach in the circumstances and not perverse. The availability of an alternative basis, such as apportionment according to net income, did not by itself justify interference.

Conclusion: The method of assessment was upheld and no interference with the orders under challenge was warranted.

---