“agricultural income”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(1A) / Rule 7, 7A, 7B(1), 7B(1A), 82,868 judgments

The decision most relied on for agricultural income is CIT v. Ghanshyam (HUF) (315 ITR 1), cited in 363 judgments on BharatTax.

Leading authorities on agricultural income

CIT v. Ghanshyam (HUF)

315 ITR 1 · 2009 · Supreme Court

363

citing judgments

Interest received under Section 28 of the Land Acquisition Act, 1894, is considered part of the enhanced compensation on compulsory acquisition of land. It is taxable as 'capital gains' and not separately as 'interest income' under the head Income from Other Sources.

CIT v. Punjab State Cooperative Agricultural Development Bank Ltd.

389 ITR 68 · 2016 · High Court

192

citing judgments

Income earned by a cooperative society from investing its surplus funds in short-term deposits and securities is not attributable to its core activities and therefore not eligible for deduction under Section 80P(2)(a)(i) of the Income-tax Act.

Mavilayi Service Co-operative Bank Ltd. v. CIT

414 ITR 67 · 2019 · High Court

190

citing judgments

The Full Bench of the Kerala High Court held that a co-operative bank or society is not entitled to a deduction under Section 80P(2)(a)(i) of the Income-tax Act if it provides loans to non-members. This decision was subsequently overruled by the Supreme Court.

Smt. Harshila Chordia v. ITO

298 ITR 349 · 2008 · High Court

187

citing judgments

Cash receipts from customers against genuine delivery of goods or services cannot be added as unexplained cash credits under Section 68. The case also provides guidance on non-disallowance under Section 40A(3) for business payments made in specific contexts like agricultural markets.

Kerala State Co-operative Agricultural and Rural Development Bank Ltd. v. Assessing Officer

154 Taxmann.com 305 · 2023 · Supreme Court

136

citing judgments

Section 80P(4) is not applicable to a cooperative bank unless it is classified as a 'bank' under the provisions of the Banking Regulation Act, 1949. For cooperative banks not meeting this definition, the deduction for interest earned from investments in cooperative societies is available under Section 80P(2)(d) of the Income-tax Act.

CIT v. Raja Benoy Kumar Sahas Roy

32 ITR 466 · 1957 · Supreme Court

132

citing judgments

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.

Sabarkhanta Zilla Kharid Vechan Sangh Ltd. v. ClT

203 ITR 1027 · 1993 · Supreme Court

citing judgments

Co-operative societies or banks engaged in both agricultural and non-agricultural activities are entitled to deduction under Section 80P of the Income Tax Act, 1961, limited only to the profits derived from agricultural activities, not 100% of their gross profits.

CIT v. Usha Stud Agricultural Farms Ltd.

301 ITR 384 · 2008 · High Court

citing judgments

An addition cannot be made under Section 68 for cash credits if it is established that the credits do not pertain to the impugned assessment year but relate to earlier assessment years.

Judgments citing agricultural income

Vallbhbhai Nebhabhai Gojiya, at.Bankodi, Tal.Jamkalyanpur vs. Commissioner of Income-Tax (Appeals), Delhi

In the result, the appeal of the assessee is partly allowed in above terms

ITA 286/RJT/2025[2020-21]Status: DisposedITAT Rajkot31 Dec 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 286/Rjt/2025 (Assessment Year: 2020-21) Vallabhbhai Nebhabhai Gojiya, Vs. The Cit(A), Bankodi, Jam Kalyanpur, National Faceless Appeal Centre Dist: Devbhoomi, Dwarka-361315 (Nfac), Delhi – 110003 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Ajgpg9688P (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Mahesh Paun, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR

Section 142(1)Section 143(2)Section 143(3)

solitary grievance of the assessee in this appeal is that Ld. Commissioner of Appeals (NFAC) erred by not considering the fact that Agricultural income of Rs. 6,39,780/- is having recorded in the books of Vallabhbhai N. Gojiya accounts, the addition made by the assessing officer should ... assessee`s case was selected for scrutiny for assessment year (AY) 2020-21 under CASS to verify the genuineness of the agricultural income and related transactions in view of agricultural land holding and other factors. Accordingly, notice u/s 143(2) was issued on 29/06/2021, which was duly served

Vipul Arjanbhai Parmar, Mangrol vs. Income Tax Officer, Ward -1, Junagadh

In the result, appeal filed by the assessee is allowed

ITA 217/RJT/2025[2010-11]Status: DisposedITAT Rajkot31 Dec 2025AY 2010-11

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.217/Rjt/2025 िनधा"रण वष"/Assessment Year : 2010-11 बनाम/ Vipul Arjanbhai Parmar Income Tax Officer Vs C/O. Sarda & Sarda (Ca), Sakar, Ward – 1, Junagadh 1St Floor, Dr. Radha-Krishnan Road, Opp. Rajkumar College, Rajkot, Gujarat - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ditpp9286B (अपीलाथ"/Assessee) (""थ"/Respondent)

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 143(3)Section 250

duly served upon the assessee. In response to the notice, the assessee has submitted return of income declaring total income of Rs.Nil and agriculture income of Rs.4,30,700/- on 01.08.2017. Notice 4 Vipul Arjanbhai Parmar vs. ITO was 143(2) & 142(1) of the Act dated 07.08.2017 were issued ... assessee, vide, his reply dated nil received by the assessing officer on 22.11.2017, has stated that he is an agriculturist and having only agriculture income and did not maintain any books of account. The assessee has given the chart regarding agriculture income along with copy of sale bills of agriculture

Tafseer Ahmad, Lucknow vs. DDIT/ADIT(Intl Tax)Lkn, Lucknow

In the result, the appeal of the assessee stands allowed for statistical purposes

ITA 517/LKW/2025[2017-18]Status: DisposedITAT Lucknow31 Dec 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastava

For Respondent: Shri R.R.N. Shukla, D.R

Section 115BSection 143(3)Section 69A

source of cash emanated from bona fide ITA(IT) No.517/LKW/2025 Page 4 of 8 household savings funded by foreign remittances and agricultural income. The Appellant's explanation, supported by remittance records and medical documentation, could not have been discarded on conjectural reasoning. Reliance: Dipak Balubhai Patel (HUF) v. ITO (ITAT

Mrs. Ranjana, Mrizapur vs. Assessing Officer, NFAC, Delhi

In the result, the appeal of the assessee is partly allowed

ITA 505/LKW/2025[2015-16]Status: DisposedITAT Lucknow31 Dec 2025AY 2015-16

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2015-16 Mrs Ranjana V. The Assessing Officer Village Dewapur Pachwal Nafc Post Rajapur, Aamghat Mirzapur (U.P) Tan/Pan:Aoxpr7130M (Applicant) (Respondent) Applicant By: Shri Narendra Kumar Sahu, Advocate Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 31.03.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2015-16. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed Her Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Purchased An Immovable Property Valued At Rs.60,00,000/- . The Case Of The Assessee Was Reopened Under Section 147 Of The Income Tax Act, 1961 (Hereinafter Called “The Act’) After Issuing Notice To The Assessee Under Section 148 Of The Act. However, The Assessee Neither Responded To The Notice Under Section 148 Of The Act Nor Filed Any Return Of Income For The Year Under Consideration. The Assessing Officer (Ao)

For Respondent: Shri R.R.N. Shukla, D.R

Section 142(1)Section 147Section 148Section 250Section 69

submitted that the NFAC had erred in sustaining the addition to the extent of Rs.7.30 lakhs, as the assessee’s father enjoyed agricultural income as well as also had accumulated savings, which were deposited in the bank to the tune of Rs.6.00 lakhs. It was further submitted that another ... concerned, it is seen that the NFAC has recorded a categorical finding that the assessee has not furnished any document/evidence to establish receipt of agricultural income in the hands of the father. Before me also, no evidence of agricultural income has been brought on record. There is no proof

Rajendra Kumar Shet, Raichur vs. Income Tax Officer, Ward-1, Raichur

The appeal of the assessee is allowed with above directions

ITA 816/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2017-18

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Subramanian, Jt.CIT (DR)(ITAT), Bengaluru

Section 133Section 143(3)Section 69A

filed his return of income for AY 2017 – 18 on 1 November 2017 declaring total income of ₹ 525,890 and has also shown agricultural income of ₹ 1,491,503/–. The case was selected for scrutiny. As the assessee is engaged in the trading of gold, silver, jewellery and watches ... cash book, Ledger accounts, sale and purchase registers, copy of the VAT returns and bank statements were also produced. The details of the agricultural income was also submitted. 4. The assessee was asked to explain the cash deposits and credit made in the bank account during the financial year

Mahent Baba Ishwar Shah, Kalanaur, Rohtak vs. PCIT, Rohtak

In the result, the appeal of the assessee is allowed

ITA 2297/DEL/2025[2020-21]Status: DisposedITAT Delhi30 Dec 2025AY 2020-21

Bench: Shri M. Balaganesh & Shri Raj Kumar Chauhanassessment Year : 2020-21 Mahent Baba Ishwar Shah, Vs. Pcit, Dera Mahent Baba Ishwar Shah, Rohtak, Near Bus Stand, Income Tax Office, Near Pnb Bhiwani Road, Rohtak. Kalanaur, Distt. Rohtak, Rohtak. Pan: Abspi7267G

For Appellant: Shri Navin Gupta, Advocate &For Respondent: Shri Jitendra Singh, CIT-DR

Section 142(1)Section 143(1)(a)Section 144Section 263Section 69A

Rs.8,70,201/- after claiming deduction under Chapter VIIA of the Act. The assessee has also shown an income of Rs.98,23,352/- as agricultural income after claiming expenses of Rs.48,12,360/- making out the gross receipts corresponding to the agricultural profits to the tune of Rs.1 ... during the assessment proceedings, a show cause notice was issued u/s 144 of the Act seeking explanation with regard to the agricultural income claimed as exempt by the assessee along with other relevant inquiries. Further, statutory notices u/s 142(1) of the Act dated 2nd November, 2021 was also issued

Sanjay Bhaskar, New Delhi vs. DCIT Central Cir 13, New Delhi

In the result, appeal of the assessee is allowed

ITA 1655/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Dec 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 132Section 132(1)Section 139(1)Section 142(1)Section 143(2)Section 153ASection 250Section 6(1)

admission that the amount in question was laid out or expended for the cultivation, upkeep or maintenance of immature plants from which no agricultural income was derived during the previous year. An admission is an extremely important piece of evidence but it cannot be said that it is conclusive

Sanjay Bhaskar, New Delhi vs. DCIT Central Cir 13, New Delhi

In the result, appeal of the assessee is allowed

ITA 1654/DEL/2024[2019-20]Status: DisposedITAT Delhi30 Dec 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 132Section 132(1)Section 139(1)Section 142(1)Section 143(2)Section 153ASection 250Section 6(1)

Sanjay Bhaskar, New Delhi vs. DCIT Central Cir 13, New Delhi

In the result, appeal of the assessee is allowed

ITA 1653/DEL/2024[2018-19]Status: DisposedITAT Delhi30 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 132Section 132(1)Section 139(1)Section 142(1)Section 143(2)Section 153ASection 250Section 6(1)

Sanjay Bhaskar, New Delhi vs. DCIT Central Cir 13, New Delhi

In the result, appeal of the assessee is allowed

ITA 1650/DEL/2024[2017-18]Status: DisposedITAT Delhi30 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 132Section 132(1)Section 139(1)Section 142(1)Section 143(2)Section 153ASection 250Section 6(1)

Mr. Girish Kisandas Mehta, Pune vs. ITO Ward 9 (3), Pune

In the result, appeal of the assessee is allowed for statistical purposes

ITA 1259/PUN/2025[2018-19]Status: DisposedITAT Pune29 Dec 2025AY 2018-19

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1259/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Mr. Girish Kisandas Mehta, Vs. Ito, Ward-9(3), Pune. Mehta Niwas Bhairavnath Nagar, Kusgaon, Lonavala, Maval, Pune- 410401. Pan : Akepm3983A Appellant Respondent Assessee By : Shri Bhuvanesh Kankani Revenue By Smt. N. C. Shilpa : Date Of Hearing : 17.11.2025 Date Of Pronouncement : 29.12.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.03.2025 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2018-19. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1. On The Facts & Circumstances Prevailing In The Case & As Per Provisions & Scheme Of The Income-Tax Act, 1961 ('The Act') It Be Held That The Assessment Proceedings Initiated U/S 147 Of The Act Are Invalid Since The Requisite Approval/Sanction U/S 151(Ii) Of The Act Is Not Taken. Accordingly, The Assessment Proceedings So Initiated Be Kindly Annulled & Appellant Be Granted Just & Proper Relief In This Respect.

For Appellant: Shri Bhuvanesh Kankani

Section 139Section 147Section 148Section 151Section 2(14)Section 80C

Facts of the case, in brief, are that the assessee is an individual deriving income from rent, interest income on fixed deposits and agricultural income and has not furnished return of income u/s 139 of the IT Act. On the basis of information of financial transactions of the assessee available

Digamber Shankar Naik, Karwar vs. ITO, Ward - 2, Karwar

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 296/PAN/2019[2012-13]Status: DisposedITAT Panaji26 Dec 2025AY 2012-13

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

addition of (i) excess value of the property over recorded value in books and (ii) credits of 2 ITA. No.281&296/PAN/2019 Digamber Shankar Naik. agricultural income made by the assessing officer. Further the assesee has raised three additional grounds of appeal. 3. The brief facts of the case are that ... assessee has filed the return of income for the A.Y 2011-12 on 20.09.2011 disclosing a total income of Rs.2,89,681/- and agricultural income of Rs.85,600/-.Subsequently the assessee has filed revised return of income on15.06.2012 disclosing a total income of Rs.3,54,241/-and agricultural income

Digamber Shankar Naik, Karwar vs. ITO, Ward - 2, Karwar

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 281/PAN/2019[2011-12]Status: DisposedITAT Panaji26 Dec 2025AY 2011-12

Bench: SHRI PAVAN KUMAR GADALE (Judicial Member)

Shri Ram Gour, Shivpuri vs. Income Tax Officer Ashok Nagar, Gwalior

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

ITA 486/AGR/2025[2017-18]Status: DisposedITAT Agra24 Dec 2025AY 2017-18

Bench: : Shri S. Rifaur Rahmanassessment Year: 2017-18

Section 143(3)Section 69A

attended the office of the Assessing Officer and submitted that the assessee has made the cash deposit during demonetization period out of his agricultural income. Not satisfied with the submission of the assessee, the Assessing Officer proceeded to make addition u/s. 69A of the Act. 3. Against the above said

Gajendra Singh, Vidisha vs. Commissioner of Income-Tax (Appeals), NFAC, Delhi

Appeal is allowed for statistical purpose

ITA 285/IND/2025[2018-19]Status: DisposedITAT Indore24 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal

Section 144Section 147Section 69A

respect of cash transactions in bank a/c and a further addition of Rs. 3,00,000/- by disallowing claim of agricultural income having been earned by assessee. He submitted that the assessee has collected all required details/document to satisfy the AO and therefore ready and willing to make a proper

Ranjeet Singh, Kurukshetra vs. ITO Ward-1, Kurushetra, Kurukshetra

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 271/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh24 Dec 2025AY 2020-2021

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Abhinav Gupta, Advocate (Virtual Mode)For Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 144Section 144BSection 69A

quantum of additions made by the AO and upheld by the Ld. CIT(A) is disputed. 1.1 Treatment of Gross Agricultural Income as Undisclosed Income:- That the L'd CIT(A) erred in upholding the action of the Learned AO in treating the gross agricultural income ... undisclosed income, which is contrary to the facts and the law. The assessee had duly disclosed the agricultural income in the return of income, supported by relevant documentation and evidence. The credits in the bank account were declared as receipts from agricultural activities, primarily from the sale of sugarcane

Ramanbhai Harmanbhai Patel, Anand vs. The ITO, Ward-2, Anand

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 1555/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad24 Dec 2025AY 2012-13

Bench: Shri Suchitra Kambleassessment Year 2012-13

For Appellant: Shri Jigar Adhyaru, A.RFor Respondent: Shri Suresh Chand Meena, Sr. D.R

Section 144Section 148

assessee filed return of income for assessment year 2012- 13 on 21-11-2013 declaring total income at Rs. nil showing agricultural income of Rs. 1,80,800/-. On the basis of information, the Assessing Officer observed that the assessee deposited cash in the Central Bank of India amounting

Kanubhai Ramdas Patel(Prop. of Gujarat Agro Base Company), Mehsana vs. The ITO, Ward-5(2)(5), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1207/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad24 Dec 2025AY 2012-13

Bench: Ms.Suchitra R. Kambleassessment Year : 2012-13 Kanubhai Ramdas Patel The Ito, Ward- Prop: Gujarat Agro Base Company Vs 5(2)(5), Vejalpur C-1/70, Gidc Ahmedabad. Phase-Ii, Dediyasan Mehsana 384 002. Pan: Agzpp 2264 N (Applicant) (Responent) : Assessee By Shri M.K. Patel, Advocate : Revenue By Shri Suresh Chand Meena, Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 01/12/2025 घोषणा क" तारीख /Date Of Pronouncement: 24 /12/2025

Section 10(38)Section 132Section 142(1)Section 147Section 151Section 250

facts and in law the learned NFAC-CIT(A) has grievously erred in confirming the addition of Rs.3,66,900/- made by treating the agricultural income as unexplained. 3. Brief facts of the case are that the assessee is proprietor of M/s. Gujarat Agro Base Co., which is engaged ... income for A.Y. 2012–13 on 29.09.2012, declaring total taxable income at Rs.6,64,430/- and exempted income of Rs.4,12,031/-, being agricultural income. The assessee also claimed LTCG on sale of shares of Rs.26,16,889/- as exempt income u/s 10(38) of the Act. 4. A search

Prabhakar Reddy Basireddy, Nalgonda vs. DCIT., Central Circle-1(1), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1592/HYD/2025[2022-23]Status: DisposedITAT Hyderabad24 Dec 2025AY 2022-23

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 132Section 147Section 148

dated 29/11/2023. In compliance, the assessee filed his return of income on 28/02/2024 declaring an income of Rs. 3,88,570/-, and agricultural income of Rs. 1,80,400/-. 4. During the course of the assessment proceedings, the AO observed that in the course of the search proceedings conducted under

Prabhakar Reddy Basireddy, Nalgonda vs. DCIT., Central Circle-1(1), Hyderabad

In the result, both the appeals filed by the assessee in ITA Nos

ITA 1591/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Section 132Section 147Section 148