Agricultural income evidence prevailed over estimate, and the section 69A addition was deleted for lack of sustainable basis.

Agricultural income supported by khasra girdawari, Form J and crop records was accepted at the higher figure because the evidence showed cultivation of both Rabi and Kharif crops, including paddy, and sale proceeds exceeded the estimate adopted in assessment. A mistaken higher disclosure in the return was not treated as conclusive against the assessee, since tax liability had to follow the correct legal and factual position. On that basis, the agricultural income was taken at Rs. 10,50,000 and the addition under section 69A was deleted.

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Issues: Whether the assessee's agricultural income for Assessment Year 2017-18 was to be taken at Rs. 10,50,000/- and the addition made under section 69A was liable to be deleted.

Analysis: The assessment proceeded on an estimated agricultural income of Rs. 5,00,000/- based mainly on wheat cultivation, but the record showed that the assessee also cultivated paddy and the land yielded produce from both Rabi and Kharif crops. The material on record, including khasra girdawari and Form J, supported a higher agricultural income, and the aggregate sale proceeds reflected in the documents were substantially above the figure adopted by the Assessing Officer. The fact that the return originally disclosed a higher agricultural income by mistake did not make the excessive disclosure conclusive against the assessee, since taxability must follow the correct legal and factual position.

Conclusion: The agricultural income was rightly to be accepted at Rs. 10,50,000/- and the addition of Rs. 15,50,000/- under section 69A was not sustainable; the assessee succeeded.

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