The Tribunal held that the details of expenditure and quantification of goods could not be questioned from the purchasers or traders of the goods because they were general merchants and commission agents, and not farmers from whom the Assessing Officer could expect details. For the assessee’s own case for the AY 2015-16, the assessee agreed to disallowance of 10 per cent. of the agricultural income returned. Since the assessee had not explained the expenses incurred in earning the agricultural income, it was appropriate to make a disallowance at 25 per cent. of the expenses incurred for earning the agricultural income. Therefore, the Assessing Officer was to make a disallowance to the extent of 25 per cent. of the expenditure on account of earning of agriculture income. (AY.  2014-15)