PLANTS PLANET,NAVI MUMBAI vs. INCOME TAX OFFICER, NAVI MUMBAI

ITA 2471/MUM/2026Status: DisposedITAT Mumbai17 June 2026AY 2017-201820 pages
AI SummaryRemanded

What were the facts?

The assessee firm treated income from nursery activities as agricultural income, claiming exemption under Section 10(1). The lower authorities treated this income as business income. The assessee argued that Explanation 3 to Section 2(1A) specifically deems income from saplings/seedlings grown in a nursery as agricultural income.

What did the Tribunal hold?

The Tribunal found that the lower authorities relied on insufficient evidence and the assessee also failed to produce supporting material. Therefore, the matter was restored to the Assessing Officer for fresh adjudication.

What were the issues?

Whether income derived from nursery activities, specifically from saplings and seedlings, qualifies as agricultural income under Section 2(1A) read with Explanation 3 and is thus exempt under Section 10(1).

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, MUMBAI BENCH “J (SMC

Before: SHRI OM PRAKASH KANT & SHRI ANIKESH BANERJEE

For Appellant: Shri Pradeep Hathi, CA
For Respondent: Shri Aditya Rai (SR DR)
Hearing: 11/06/2026

PER OM PRAKASH KANT, AM

This appeal by the Assessee firm is directed against order dated 31.12.2025, passed by the learned Commissioner of Income- tax (Appeals) – National Faceless Appeal Centers- Delhi (in short, “the Ld. CIT(A)”), for the Assessment Year 2017–18, raising following grounds:

“1. Ground No. 1 Erroneous confirmation of addition treating agricultural income as business income

Plants Planet 2

1.

The learned Commissioner of Income

1.

The learned Commissioner of Income-tax (Appeals), NFAC, erred in law tax (Appeals), NFAC, erred in law and on facts in confirming t

The order continues below.

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