Assessee is  engaged in business of sale of mushroom spawns and claimed income from same as exempt, as per provisions of S. 10(1) of the Act being in nature of agricultural income.  AO disallowed the  claim on the ground that the assessee has not produced any evidence to demonstrate  any mycelium grown on same as claimed by assessee. On appeal the Tribunal held that whether findings of revenue called into question very claim of assessee that it had grown spawn  accordingly  the matter was to be restored to file of A.O. with direction to first determine fact whether spawn was actually grown by assessee, taking into consideration evidences filed by assessee, and if so by what process. If it was found that assessee was indulging in activity of growing spawns, issue of claim of exemption under S. 10(1), be thereafter decided in accordance with law.  As regards reassessment is Tribunal held that the reassessment is held to be valid. (AY. 2011-12 to 2014-15).