Agricultural income accepted where land ownership was undisputed and later-year income was also accepted, deleting the addition.

Undisputed ownership of agricultural land, together with acceptance of similar agricultural income in the immediately following assessment years, supported the assessee's claim that the amount represented agricultural income. On those surrounding probabilities, the claim could not be rejected merely for want of further evidence, and there was no rational basis to treat the amount as income from undisclosed sources. The addition was therefore deleted.

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Issues: Whether the sum of Rs. 7,500 claimed by the assessee as agricultural income was liable to be assessed as income from undisclosed sources.

Analysis: The assessee owned agricultural land, and the fact of such ownership was not in dispute. Similar agricultural income declared in the immediately following assessment years had been accepted by the Revenue. In these circumstances, and having regard to the probabilities of the case, there was no rational basis for rejecting the assessee's claim for the year in question merely for want of further evidence.

Conclusion: The assessee's claim of agricultural income was accepted and the addition treating the amount as income from undisclosed sources was deleted.

Ratio Decidendi: Where ownership of agricultural land is undisputed and the claimed agricultural income is consistent with income accepted in subsequent years, the claim cannot be rejected as undisclosed income merely on a lack of further evidence when the surrounding probabilities support the assessee.

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