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Issues: Whether the agricultural income from the assessee's coffee crop could be computed on the point basis instead of the cash method regularly employed, in the absence of a recorded opinion by the Agricultural Income-tax Officer that the income could not properly be deduced from that method, and whether alleged consent to the assessment order validated the computation.
Analysis: Section 7 of the Mysore Agricultural Income-tax Act, 1957 makes computation of agricultural income mandatory according to the method of accounting regularly employed by the assessee. The first proviso permits departure only when the Agricultural Income-tax Officer forms the opinion that the income cannot properly be deduced therefrom, and that opinion is a jurisdictional precondition. The second proviso dealing with coffee crop only prescribes the valuation basis where the first proviso is attracted; it does not confer an unrestricted power to ignore the assessee's regular accounting method. The corresponding rule under the Mysore Agricultural Income-tax Rules, 1957 operates on the same footing. Further, the record did not show any real consent by the assessee to computation on the point basis; mere signature on the assessment order was insufficient.
Conclusion: The computation on the point basis was invalid, and the assessments had to be made according to the cash method regularly employed by the assessee.
Ratio Decidendi: Departure from the assessee's regular method of accounting is permissible only upon the assessing authority's recorded opinion that income cannot properly be deduced from that method, and a qualifying proviso cannot be used to dispense with that statutory precondition.