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Revision filed by an assessee to agricultural income-tax under section 78 of the Kerala Agricultural Income-tax Act, 1991 challenging an order affirming an assessment for the year 1985-86 based on unreliable accounts and low yield from estates. Analysis: The petitioner, a private limited company, reported a total loss for the assessment year, owning Graceland Estate and Janasree Estate. The Agricultural Income-tax Officer rejected the accounts as they were not maintained in the usual course of business, written at a stretch, and showed low yield. The income from slaughter tapping in Keezhar and Parayankulam Estates was also disputed. The assessing authority estimated income based on comparable cases, setting the latex value at Rs. 140 per tree. The Commissioner affirmed this order, noting discrepancies in the crop register and lack of evidence for claimed expenses. The rejection of accounts and income estimation were upheld, leading to the revision in court. The court highlighted that the assessing authority had valid reasons for rejecting the accounts, including irregular maintenance and low yield. The Commissioner also found the accounts unreliable due to discrepancies. The rejection was deemed justified based on factual findings. The contention that yield estimation should be based on the agreement for slaughter tapping was dismissed as the agreement lacked credibility, being unregistered and not presented during inspection. The assessing authority and Commissioner determined the income based on nearby cases, setting the tree value at Rs. 140, a factual decision upheld by the court. The court found no legal errors in the Commissioner's decision, leading to the dismissal of the revision. In conclusion, the court upheld the Commissioner's decision, emphasizing the factual basis for rejecting accounts and estimating income. The lack of credibility in the agreement for slaughter tapping and the reliance on comparable cases for income estimation were deemed valid. The court found no legal errors warranting interference under section 78 of the Agricultural Income-tax Act, resulting in the dismissal of the revision.
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