The assessee is a company engaged in the business of 

manufacture of bulk drugs. It also derives income from growing of 

“Edible white button mushrooms” ( Mushroom) under the name and 

style of ‘Premier Mushroom’. The assessee was treating the income 

from growing mushrooms as “income from agriculture” and hence 

exempt u/s. 10(1) of the Income Tax Act, 1961 [Act]. A survey operation 

u/s. 133A of the Act was conducted on 23rd September, 2013, at the 

mushroom growing unit of the assessee-company located at Kallakal – 

Village, Toopran – Mandal, Medak – District, Telangana. The Ld.Assessing 

Officer (AO) records that the survey was conducted to verify the process 

of mushroom growing by the assessee-company. During the course of 

survey, statements were recorded from Mr. K. Jagadish, Vice President 

(Operations) and Mr. C. Rajesh, another Vice President of the company. 

During the course of scrutiny proceedings, in reply to the queries raised 

by the AO, the assessee made various submissions

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