PHI SEEDS PVT. LTD.,HYDERABAD vs. ADDL. CIT, SPECIAL RANGE- 7 , NEW DELHI

ITA 7375/DEL/2018Status: DisposedITAT Delhi13 May 2026AY 2014-1568 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the denial of exemption for agricultural income. It found that the assessee did not perform basic agricultural operations like tilling and sowing, and the income was derived from procurement of seeds rather than from the land itself.

What were the facts?

The assessee, a subsidiary of a US company, claimed exemption for agricultural income derived from procuring, processing, and selling seeds. The Assessing Officer (AO) and Commissioner of Income Tax (Appeals) denied this exemption, holding that the assessee's activities did not constitute basic agricultural operations.

What were the issues?

Whether the assessee's activities of procuring, processing, and selling seeds qualify as agricultural operations for exemption under Section 10(1) of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 10(1),Section 2(1A)

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Cases cited in this judgment(1)Show list

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Heard together (3 matters)

ITA No.1575/DEL/2018
ITA No. 7375/DEL/2018
ITA No.9205/DEL/2019

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘T’: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER [Assessment Year: 2013-14] Corteva Agriscience Seeds Private Limited (Formerly known as PHI Seeds Private Limited), V-Ascends, Atria Block, 12th Floor, Plot No.17, Software Units Layout, Madhapur, Hyderabad Telangana, 500081 PAN-AACCP3920F Special Range-7, Room No.211, C.R. Building, Delhi-110002 Revenue [Assessment Year: 2014-15] Corteva Agriscience Seeds Private Limited (Formerly known as PHI Seeds Private Limited), V-Ascends, Atria Block, 12th Floor, Plot No.17, Software Units Layout, Madhapur, Hyderabad Telangana, 500081 PAN-AACCP3920F Special Range-7, Room No.211, C.R. Building, Delhi-110002 Revenue [Assessment Year: 2015-16] Corteva Agriscience Seeds Private Limited (Formerly known as PHI Seeds Private Limited), V-Ascends, Atria Block, 12th Floor, Plot No.17, Software Units Layout, Madhapur, Hyderabad Telangana, 500081 PAN-AACCP3920F Assessee Vs Additional Com

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