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ITAT allowed the assessee's appeal, deleting the addition made by the AO on account of alleged under-declaration of agricultural expenses. The AO had estimated agricultural expenditure at 40% of gross agricultural receipts solely by relying on an earlier ITAT ruling in a third-party case, without disputing the assessee's disclosed receipts or the evidentiary support for expenses at 32.83%. ITAT held that agricultural expenditure is fact-specific and cannot be mechanically fixed at a uniform percentage, and that the AO's action was based on mere presumption without any corroborative material to show higher actual expenditure. Consequently, the impugned addition was unsustainable and stood fully deleted.
ITAT allowed the assessee's appeal, deleting the addition made by the AO on account of alleged under-declaration of agricultural expenses. The AO had estimated agricultural expenditure at 40% of gross agricultural receipts solely by relying on an earlier ITAT ruling in a third-party case, without disputing the assessee's disclosed receipts or the evidentiary support for expenses at 32.83%. ITAT held that agricultural expenditure is fact-specific and cannot be mechanically fixed at a uniform percentage, and that the AO's action was based on mere presumption without any corroborative material to show higher actual expenditure. Consequently, the impugned addition was unsustainable and stood fully deleted.
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