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    <title>2025 (2) TMI 1940 - ITAT COCHIN</title>
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    <description>An addition based on disallowing 50% of agricultural income could not be sustained where the assessee&#039;s books of account had not been rejected and the assessment record did not clearly establish that the income was treated as an application of income. The appellate record showed that the dispute turned on the treatment of the agricultural income without the necessary foundational rejection of books. The matter was therefore set aside to the CIT(A) for fresh adjudication in accordance with law after granting the assessee a reasonable opportunity of hearing.</description>
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      <description>An addition based on disallowing 50% of agricultural income could not be sustained where the assessee&#039;s books of account had not been rejected and the assessment record did not clearly establish that the income was treated as an application of income. The appellate record showed that the dispute turned on the treatment of the agricultural income without the necessary foundational rejection of books. The matter was therefore set aside to the CIT(A) for fresh adjudication in accordance with law after granting the assessee a reasonable opportunity of hearing.</description>
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