Penalty Upheld for Misclaiming Agricultural Income u/s 271(1)(c); Assessee Failed to Prove Legitimate Farming Activity.

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....Penalty u/s 271(1)(c) - Assessee wrongly claimed the income as agricultural income - One of the strange features in the kind of arrangement or documentation of the assessee is that in case of no yield or damage of crop, the expenses on labour or service or fertilizer etc. has to be borne by the farmer because in absence of no crop, there would be no procurement price to the farmer and the farmer will get nothing. In such circumstances, how the assessee could explain that the cultivation has been done by the company. Another strange feature is that how the assessee can claim as cultivator as its name is not appearing in the revenue land records - penalty imposed by the AO upheld - AT....