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    <title>ITAT deletes presumptive addition for agricultural expenses, holds AO cannot apply uniform percentage without evidence</title>
    <link>https://www.taxtmi.com/highlights?id=94442</link>
    <description>ITAT allowed the assessee&#039;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&#039;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&#039;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.</description>
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    <pubDate>Mon, 24 Nov 2025 08:57:51 +0530</pubDate>
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      <title>ITAT deletes presumptive addition for agricultural expenses, holds AO cannot apply uniform percentage without evidence</title>
      <link>https://www.taxtmi.com/highlights?id=94442</link>
      <description>ITAT allowed the assessee&#039;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&#039;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&#039;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.</description>
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      <pubDate>Mon, 24 Nov 2025 08:57:51 +0530</pubDate>
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