Assessee filed its return of income claiming agricultural income from sale of coffee. Case was selected for limited scrutiny under CASS to verify substantial increase in agricultural income. PCIT invoked revisionary jurisdiction  on ground that as per rule 7B, 25 per cent of income derived from sale of coffee grown and cured and 40 per cent of income derived from sale of coffee grown, cured and roasted and grounded had to be deemed as business income. On appeal, the Tribunal held that the Assessing Officer, vide notice under section 142(1), specifically asked for details of the nature and type of agricultural income along with details of the process undertaken and documentary evidence with regard to the mode of sale of agricultural proceeds along with a copy of contracts, if any.  Assessee had specifically replied that coffee was picked, dried and sold as raw coffee without curing. Since a query was raised by the Assessing Officer during the original assessment with respect to agricultural income, which was responded by assessee, invocation of section 263 was not justified.  (AY. 2020-21)