Undisclosed income of the assessee - bogus sale of agricultural...

Undisclosed income of the assessee - bogus sale of agricultural produce - preponderance of probability theory - The Tribunal noted that the AO had not properly considered the nature of the appellant’s income and the agricultural evidence provided. It was observed that the lower authorities failed to appreciate the complexities of agricultural income and its proof, particularly in light of the transactions during the demonetization period. - The statements recorded by the AO, including those of a person responsible for the appellant's agricultural affairs, did not conclusively prove that the agricultural receipts were manipulated. - The Tribunal allowed the appeal, setting aside the addition of income.