Held that the assessee was well within its right to claim refund of taxes which was not granted though the tax liability had been determined at nil. The action of the Assessing Officer while disposing of the assessee’s rectification application, recomputing the book profits by including the agricultural income was not sustainable in the eyes of law. There was no notice to the assessee before enhancing the income and the Assessing Officer in his zeal of disposing of the rectification application had failed to appreciate and consider the unambiguous provisions wherein the agricultural income was exempt from the book profits for the purposes of computing the minimum alternate tax liability. The order of the Commissioner (Appeals) is set aside.(AY.2012-13, 2013-14)