Agricultural receipts supported by records cannot be estimated as non-agricultural income without contrary material.

Detailed agricultural accounts, supported by receipts, expenditure records and sales evidence including supplies to the Food Corporation of India, were accepted as showing agricultural income. In the absence of material proving that the credits were non-agricultural, and given that year-to-year yield fluctuations were not abnormal enough to justify rejection of the accounts, an estimated substitution of income was unwarranted. The estimated addition treating part of the agricultural receipts as non-agricultural income was therefore deleted, and the departmental appeal failed.

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Issues: Whether the estimated addition treating part of the assessee's agricultural receipts as non-agricultural income was justified.

Analysis: The assessee maintained detailed accounts for agricultural operations, including particulars of receipts and expenditure. The sales were supported by details, including sales to the Food Corporation of India, and there was no material to show that the credits represented anything other than agricultural income. The income pattern over several years showed fluctuations, and the year's yield was not shown to be so abnormal as to warrant rejection of the accounts or substitution of an estimated figure.

Conclusion: The addition was not sustainable and was deleted. The departmental appeal was dismissed.

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