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ITAT allowed the assessee's appeal, holding that conversion of grapes into raisins constituted an agricultural activity. The Tribunal found no evidence to rebut the assessee's factual claim of using traditional conversion methods, noted prior revenue acceptance of such conversion as agricultural income in AY 2018-19, and relied on a governmental circular indicating an agriculturist supplying raisins is exempt from GST registration. Consequently, the Tribunal held the Assessing Officer's bifurcation of total agricultural receipts on a 60:40 basis - treating 60% as business income - was unsustainable, directed deletion of the 60% addition, and remitted the assessment adjustment accordingly.
ITAT allowed the assessee's appeal, holding that conversion of grapes into raisins constituted an agricultural activity. The Tribunal found no evidence to rebut the assessee's factual claim of using traditional conversion methods, noted prior revenue acceptance of such conversion as agricultural income in AY 2018-19, and relied on a governmental circular indicating an agriculturist supplying raisins is exempt from GST registration. Consequently, the Tribunal held the Assessing Officer's bifurcation of total agricultural receipts on a 60:40 basis - treating 60% as business income - was unsustainable, directed deletion of the 60% addition, and remitted the assessment adjustment accordingly.
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