How many judgments cite CIT v. Raja Benoy Kumar Sahas Roy?

132 judgments on BharatTax cite CIT v. Raja Benoy Kumar Sahas Roy (32 ITR 466), spanning 2003 to 2026.

Which sections of the Income Tax Act does CIT v. Raja Benoy Kumar Sahas Roy come up under?

It is most often cited in judgments turning on Section 143(3), Section 2(1A), Section 10(1), Section 142(1), Section 143(2), Section 147.

CIT v. Raja Benoy Kumar Sahas Roy

32 ITR 466Supreme Court of India1957#773 most cited

What is CIT v. Raja Benoy Kumar Sahas Roy authority for?

Income is considered agricultural income, exempt under Section 10(1), only if the land undergoes a measure of cultivation involving basic primary operations prior to germination and subsequent post-germination activities requiring human skill and labour.

132

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2003 to 2026.

Also referred to as

CIT v. Raja Benoy Kumar Sahas Roy · 32 ITR 466 · Section 10(1) · Section 2(1A) · agricultural income definition · agricultural operations · cultivation · primary operations · post-germination activities · income tax exemption

Sections most often in play

Section 143(3)Section 2(1A)Section 10(1)Section 142(1)Section 143(2)Section 147 Section 2(14)Section 263

Issues it is cited on

section 2(1a)section 2(14)(iii)(a)section 115ad section 2(14)(iii)(b)section 2(14)(iii)section 2(1)section 63 section 96 section 60 section 10(1)section 2(14)transfer of capital asset

Judgments citing CIT v. Raja Benoy Kumar Sahas Roy

ASHUTOSH RAM SHEWALKAR,NAGPUR vs. INCOME TAX OFFICER WARD-5(2), NAGPUR

In the result, both the above Tax

ITA 431/NAG/2025[2014-2015]Status: DisposedITAT Nagpur01 Apr 2026AY 2014-2015

Bench: Shripawan Singh& Shrikhettra Mohan Royashutosh Ram Shewalkar Ito, Ward – 5(2) 80, North Ambazari Road, Vs Bsnl, Rttcbldg Daga Layout Nagpur – 440010 Dharmapeth, Nagpur - 440010 [Pan: Aepps8104N] Appellant / Assessee Respondent / Revenue Assessee By Shrimanoj G Moryani, Adv& Shribhavesh M. Moryani, Adv Revenue By Shrisurjit Kumar Saha, Sr. Dr Date Of Hearing 27.02.2026 Date Of Pronouncement 01.04.2026

Section 143Section 143(3)Section 2(14)Section 234ASection 250

…ot classified as an agricultural land. However, nothing of that sort is available on record. 9. The Hon'bje High Court Madrass in the case law of ShakuntalaVedachalam (369 ITR 558), considering the decision of Hon'ble Apex Court in Raja Benoy Kumar Sahas Roy (32 ITR 466), held as under :- 9. The issue involved in the above Tax Case (Appeals) lies on the narrow compass, viz, whether the lands sold by the assessee are agricultural lands and whether they are entitled to the benefit of exemption capital gains tax 10. It is on record that in a report has been submitted by the revenue authorities, it is admitted that t…

SH. DEVENDRA DUTT PANT,HARIDWAR vs. DCIT , UTTARKAHAND

Appeal is partly allowed in above terms

ITA 149/DDN/2025[2106-2017]Status: DisposedITAT Dehradun14 Jan 2026AY 2106-2017

Bench: Sh. Satbeer Singh Godara & Sh. Manish Agarwal

For Appellant: Sh. Salil Aggarwal, Sr. Adv. &For Respondent: Sh. A. S. Rana, Sr. DR

Section 133(6)Section 143(3)Section 54BSection 54E

…g the question as to what can be construed as “Agricultural land”, relevant extracts are reproduced below: “10. The first decision of this Court which considered the meaning of the expression 'agricultural land' is in CIT v . Raja Benoy Kumar Sahas Roy [1957] 32 ITR 466. But the question there was whether the income from forest land derived from sal and piyasal trees, 'not grown by human skill and labour' constitutes agricultural income? The decision that directly considered the issue, though under 5 Devendra Dutt Pant the Wealth-tax Act, 1957 is in CWT v. Officer-in-charge ( Court of Wards) [1976] 105 ITR 133 (…

MAROON ORGANIC FARMING PVT LTD.,DELHI vs. ITO,WARD-16(3), DELHI

In the result, appeal of the assessee in ITA No

ITA 2726/DEL/2024[2017-18]Status: DisposedITAT Delhi10 Dec 2025AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Ms. Ankush Kalra, Sr. DR

Section 10(1)Section 133(6)Section 143(2)Section 68

…ried out only agricultural activities. 3. It is also apparent that the company to whom the assessee has leased out the land has not earned any agricultural income. 4.3.2 The Hon'ble Apex court in the case of CAT vs. Raja Benoy Kumar has Roy (1957) reported in 32 ITR 466 (SC) has held that unless there is some measure of cultivation of land and some skilled labour is performed on the land for cultivation, the land cannot be said to have been used for agricultural purposes. It is essential that basic primary operation, prior to germination of the produce, involving expenditure of human skill and labour on the land…

M/S.A.G.BIOTECH LABORATORIES [INDIA] LTD vs. INCOME TAX OFFICER

ITTA/92/2008HC Telangana21 Nov 2025

Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA

Section 10Section 151Section 260Section 260A

…is reared on earth zr 7 for which activities, certainly contribution of human labour anLl energy are essential. 8. Our attention was then invited by learned counsel t( he decisiotl of the Supreme Court in the case of CIT v. Raja E< 1oy Kumar Sahas Roy, [1957] 32 ITR 466, which is the lead, tg case of "agriculture". It was held therein that agriculture ir its primary sense denotes the cultivation of the field and is .stricted to 7 Page 21 of 32 cultivation of the land in the strict sense of the term, meantng thereby tilling of the land, sowing of the seeds, planting and simtlar operations on the land and these a…

RAZAK ROWTHER MOHAMED SALEEM,DINDIGUL vs. ITO, WARD-1,, DINDIGUL

In the result, the appeal filed by the assessee is allowed

ITA 1731/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Oct 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1731/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Razak Rowther Mohamed Saleem, Vs. The Income Tax Officer, No. 29A, Manthinapalli Vasal Street, Ward 1, Batlagundu Road, Begampur, Dindigul. Dindigul 624 002. [Pan:Acfpm9762L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. S. Vidya, C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 10.09.2025 घोषणा की तारीख /Date Of Pronouncement : 17.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. The Assessee Raised 3 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Ms. S. Vidya, C.AFor Respondent: Ms. Gouthami Manivasagam, JCIT

Section 143(1)Section 143(2)Section 2

…e," which implies integrated activities involving human effort on the land and mere spontaneous growth or minimal intervention does not suffice. By relying upon the decisions of the Hon’ble Supreme Court in the case of CIT v. Raja benoy Kumar Sahas Roy [1957] 32 ITR 466 (SC), CIT v. Raja Ramkrishna Deo [1960] 38 ITR 671 (SC) and in the case of CIT v. Green Gold Tree Farms Pvt. Ltd. [2008] 303 ITR 113 (P&H), the ld. DR prayed to sustain the order confirmed by the ld. CIT(A). 6. We have heard both the parties and perused the material available on record. We note that the assessee has claimed agricultural income of…

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

In the result, all appeals of the assessee are partly allowed

ITA 9205/DEL/2019[2015-16]Status: DisposedITAT Delhi06 Aug 2025AY 2015-16

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 2Section 92C

…cultural activities within the meaning of the Act. It was further held that the assessee does not indulge in agricultural operations in accordance with tests laid in the judgment of the Hon’ble Supreme Court in the case of CIT Vs. Raja Benoy Kumar Sahas Roy 32 ITR 460. In view of the above, the claim of exemption under section 10 (1) of the Act amounting to Rs.124,59,41,832/- was denied to be assessee. Further, Transfer Pricing Adjustment u/s 92CA of the Act amounting to Rs.67,17,965/- was also made on account of receivables received from its Associate Enterprises (in short ‘AEs’) beyond the period of more tha…

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

ITA 7375/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Aug 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 2Section 92C

…ricultural activities within the meaning of the Act. It was further held that the assessee does not indulge in agricultural operations in accordance with tests laid in the judgment of the Hon'ble Supreme Court in the case of CIT Vs. Raja Benoy Kumar Sahas Roy 32 ITR 460. In view of the above, the claim of exemption under section 10 (1) of the Act amounting to Rs.124,59,41,832/- was denied to be assessee. Further, Transfer Pricing Adjustment u/s 92CA of the 5 ITA Nos.1575, 7375/Del/2018 ITA No.9205/Del/2019 Act amounting to Rs.67,17,965/- was also made on account of receivables received from its Associate Enterpri…

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

ITA 1575/DEL/2018[2013-14]Status: DisposedITAT Delhi06 Aug 2025AY 2013-14

Section 10Section 143(2)Section 143(3)Section 144C(13)Section 2Section 92C

…ltural activities within\nthe meaning of the Act. It was further held that the assessee\ndoes not indulge in agricultural operations in accordance with\ntests laid in the judgment of the Hon'ble Supreme Court in the\ncase of CIT Vs. Raja Benoy Kumar Sahas Roy 32 ITR 460. In\nview of the above, the claim of exemption under section 10 (1) of\nthe Act amounting to Rs.124,59,41,832/- was denied to be\nassessee. Further, Transfer Pricing Adjustment u/s 92CA of the\nAct amounting to Rs.67,17,965/- was also made on account of\nreceivables received from its Associate Enterprises (in short\n'AEs') beyond the period of mor…

ASIAN INSTITUTE OF GASTROENTEROLOGY PRIVATE LIMITED,HYDERABAD vs. DCIT., CIRCLE-1(1), HYDERABAD

In the result, appeals filed by the assessee for both the assessment years 2020-2021 and 2021-2022 are allowed

ITA 610/HYD/2025[2021-22]Status: DisposedITAT Hyderabad11 Jul 2025AY 2021-22

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, S. VenugopalFor Respondent: Shri B. Bala Krishna, CIT-DR

Section 143(3)Section 14ASection 263

…dly it is not so found by the Tribunal. The further question whether it will be agricultural income within the meaning of Section 2(1A) of the Act as elucidated by this Court in Commissioner of Income-tax, West Bengal, Calcutta Vs. Raja Benoy Kumar Sahas Roy [32 ITR 466] does not arise for consideration. It is evident from the Order of the High Court that findings recorded by the Tribunal that the appellant stopped agricultural operation in November 1982 and the receipt under consideration did not relate to any agricultural operation carried on by the appellant, were not questioned before 25 ITA.Nos.609 & 610/Hy…

MR MANISH JAGDISH BAJAJ,MUMBAI vs. PCIT-41, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 2758/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Jun 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2020-21 Mr. Manish Jagdish Bajaj Pcit-41, Mumbai Flat No. 605,606, 6Th Floor, Farm Room No. 541, Kautilya Manor Chs Adarsh Colony, Marve Vs. Bhava, C-41 To C-43, G Block, Road, Malad (West), Bandra Kurla Complex, Mumbai- 400064 Bandra (East), Mumbai- 400051 Pan No. Aghpb 6661 P Appellant Respondent

For Appellant: Mr. R A Dhyani, CIT-DRFor Respondent: Mr. Suchek Anchaliya

Section 143Section 143(3)Section 263

…agricultural by way of rent or revenue or from the performance of agricultural operations on such land. operations on such land. 6.1 The Hon’ble Supreme Court, in The Hon’ble Supreme Court, in CIT v. Raja Benoy Kumar CIT v. Raja Benoy Kumar Sahas Roy [(1957) 32 ITR 466 (SC)], laid down the cardinal [(1957) 32 ITR 466 (SC)], laid down the cardinal [(1957) 32 ITR 466 (SC)], laid down the cardinal principles principles principles governing governing governing what what what constitutes constitutes constitutes agricultural agricultural agricultural income, income, income, emphasising that basic agricultural operatio…

MANISHA ASHUTOSH SHEWALKAR,NAGPUR vs. INCOME TAX OFFICER WARD 5(3), NAGPUR

In the result, assessee’s appeal stands allowed

ITA 67/NAG/2025[2014-15]Status: DisposedITAT Nagpur04 Apr 2025AY 2014-15

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Abhay Y. Marathe

Section 133(6)Section 143(3)Section 147Section 148Section 2(14)Section 234A

…classified as an agricultural land. However, nothing of that sort is available on record. 9. The Hon'ble High Court of Madras in the case law of Shakuntala Vedachalam (369 ITR 558), considering the decision of Hon'ble Apex Court in Raja Benoy Kumar Sahas Roy (32 ITR 466), held as under: - 9. The issue involved in the above Tax Case (Appeals) lies on the narrow compass, viz., whether the lands sold by the assessees are agricultural lands 7 Manisha Ashutosh Shewalkar ITA no.67/Nag./2025 and whether they are entitled to the benefit of exemption from capital gains tax. 10. It is on record that in a report has been s…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4,, NAGPUR vs. SONU MONU AGRO PRIVATE LIMITED, NAGPUR

In the result, Department's appeal stands dismissed

ITA 62/NAG/2024[2020-21]Status: DisposedITAT Nagpur03 Mar 2025AY 2020-21

Section 10(1)Section 143(2)Section 14A(1)

…Pvt. Ltd. ITA no.62/Nag./2024 activities therefore. the expenses amounting to Rs. 12,90.80.355/- and proportionate portion of depreciation of Rs 4,20,23,114/- is accepted. 2. The Hon'ble Supreme Court in the case of CIT Vs. Raja Benoy Kumar Sahas Roy (1957) [32 ITR 466] held that, income derived from some measure of cultivation of land with some expenditure of human skill and labour, renders the profit derived from the product agriculture income which would be exempt u/s. 2(1A) of the Act. In the case of CIT Vs. Kokine Dairy (1938) [6 ITR 502], it was held that the term 'agriculture' does not cover activities re…

A T AND S INDIA PRIVATE LIMITED,NANJANGUD,MYSORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX,KOLKATA-2, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 1220/KOL/2024[2018-2019]Status: DisposedITAT Kolkata21 Jan 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Pcit, Kolkata-2 A T & S India Private Limited Aaykar Bhavan, P-7, 12A, Industrial Area Nanjangud Chowringhee Square, Vs. H.O, Mysore-571301, Karnataka Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aaeca2930J Assessee By : Shri Anup Sinha, Ar Revenue By : Shri Abhijit Kundu, Dr Date Of Hearing: 09.12.2024 Date Of Pronouncement : 21.01.2025

For Appellant: Shri Anup Sinha, ARFor Respondent: Shri Abhijit Kundu, DR

Section 143(3)Section 144CSection 263

…loss of agricultural income and, admittedly, it is not so found by the Tribunal. The further question whether it will be agricultural income within the meaning of section 2(1A) of the Act as elucidated by this Court in CIT v. Raja Benoy Kumar Sahas Roy[1957] 32 ITR 466 does not arise for consideration. It is evident from the order of the High Court that the findings recorded by the Tribunal that the appellant stopped agricultural operation in November 1982 and the receipt under consideration did not relate to any agricultural operation carried on by the appellant, were not questioned before it. Though we do not…

LOKESH KUMAR AGGARWAL,DELHI vs. ITO,WARD-45(5), DELHI

In the result, all appeals of the assessee are partly allowed

ITA 1575/DEL/2023[2012-13]Status: DisposedITAT Delhi20 Jan 2025AY 2012-13

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 2Section 92C

KILKOTAGIRI AND THIRUMBADI PLANTATIONS LTD,CALICUT vs. THE ACIT CIRCLE-2(1) , KOZHIKODE

In the result, the grounds of appeal filed for the A

ITA 371/COCH/2023[2013-14]Status: DisposedITAT Cochin12 Nov 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri R V Veeramani, CAFor Respondent: Smt. Leena Lal, Snr.AR

Section 115JSection 40Section 43B

…R 182), there is no capital gains exigible to tax on the sale of old and unyielding rubber trees. If that be so, what is not taxable under the normal provisions should not be taxed invoking sec. 115JB. 4) The Supreme Court in CIT Vs. Raja BenoykumarSahas Roy (32 ITR 466), held that income from trees planted and nurtured will be agricultural income. Again, the SC has, in CIT Vs. All India Tea and Trading Co. Ltd, (219 ITR 544) held that compensation received on requisition of agricultural land amounted to agricultural income.lf that be so, such amount has to be excluded for purpose of book profits u/s 115JA. This…

KILKOTAGIRI AND THIRUMBADI PLANTATIONS LTD,CALICUT vs. THE ACIT CIRCLE-2(1) , KOZHIKODE

In the result, the grounds of appeal filed for the A

ITA 370/COCH/2023[2012-13]Status: DisposedITAT Cochin12 Nov 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri R V Veeramani, CAFor Respondent: Smt. Leena Lal, Snr.AR

Section 115JSection 40Section 43B

KILKOTAGIRI AND THIRUMBADI PLANTATIONS LTD,CALICUT vs. THE ACIT CIRCLE-2(1) , KOZHIKODE

In the result, the grounds of appeal filed for the A

ITA 369/COCH/2023[2008-09]Status: DisposedITAT Cochin12 Nov 2024AY 2008-09

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri R V Veeramani, CAFor Respondent: Smt. Leena Lal, Snr.AR

Section 115JSection 40Section 43B

FRESH BOWL HORTICULTURE PRIVATE LIMITED,MUMBAI vs. ITO, MUMBAI

In the result, appeal of the assessee is allowed

ITA 3049/MUM/2024[2020-21]Status: DisposedITAT Mumbai14 Oct 2024AY 2020-21

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri K. Gopal, ARFor Respondent: Shri Ankush Kapoor, CIT, DR

Section 10(1)Section 143(3)Section 2

…ssing Officer further relied on following case laws to conclude that the process or activities undertaken by the assessee are not agricultural in nature: a. Chander Mohan v. ITO (ITA No. 377 and 389 (Chd.) of 2012) b. CIT v. Raja Benoy Kumar Sahas Roy (1957) 32 ITR 466 (SC) c. Smt. Manyam Meenak shamma v. CWT (1967) 63 ITR 534 (AP) Syed Rafiquar Rahman v. CWT (1970) 75 ITR 318 (Pat.) d. CIT v. Green Gold Tree Farmers (P.) Ltd. 2007 Tax LR 609 (Uttranchal) e. Ms Blue Mount Food Products Limited v. ITO (ITA No. 1128 (Bang.) of 1983) 3.2. On the basis of the above cited case laws, ld. Assessing Officer made the fo…

MADHU VELAYUDHAN,HYDERABAD vs. INCOME TAX OFFICER, WARD-11(1), HYDERABAD

In the result, ITA No.225 & 226/Hyd/2024 are allowed in part and ITA

ITA 227/HYD/2024[2016-17]Status: DisposedITAT Hyderabad19 Sept 2024AY 2016-17

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.225, 226 & 227/Hyd/2024 (निर्धारण वर्ा/Assessment Years:2015-16, 2016-17)

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Kumar Pranav, CIT-DR

Section 143(3)Section 2Section 263

…ssee is fitting into the term "Agricultural Income" defined in Sec.2(1A) of the I.T. Act. 8. The learned Commissioner of Income-Tax (Appeals) erred in holding that the decision of the Supreme Court in the case of CIT Vs Raja Benoy Kumar Sahas Roy reported in 32 ITR 466 (SC) would apply to the facts of the case. 9. The learned Commissioner of Income-Tax (Appeals) erred in not following the decision of the Special Bench of the jurisdictional Hon'ble ITAT, Hyderabad in the case of CIT Vs Inventaa Chemical Industries Ltd. in ITA No.1015 to 1018/Hyd/15 vide order dated 9.7.2018 which is placed before him. 10. The l…

MADHU VELAYUDHAN,HYDERABAD vs. ITO., WARD-11(1), HYDERABAD

In the result, ITA No.225 & 226/Hyd/2024 are allowed in part and ITA

ITA 226/HYD/2024[2016-17]Status: DisposedITAT Hyderabad19 Sept 2024AY 2016-17

Bench: Shri K. Narasimha Chary & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.225, 226 & 227/Hyd/2024 (निर्धारण वर्ा/Assessment Years:2015-16, 2016-17)

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: Shri Kumar Pranav, CIT-DR

Section 143(3)Section 2Section 263

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