“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

Ramkrishna Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income-Tax, Circle 26(1), Mumbai

ITA 6544/MUM/2025[2013-14]Status: DisposedITAT Mumbai24 Dec 2025AY 2013-14

Bench: Shri Amit Shukla, Jm & Shri Arun Khodpia, Am

For Appellant: Ms. Vasanti Patel, Adv. & MrFor Respondent: Assessee by

Section 10(34)Section 11Section 11(5)Section 12ASection 13(1)(d)Section 143(3)Section 164(2)Section 35ASection 80

dealing with an identical issue has held in para 9 as under “So far as question No.4 of paragraph No. 3 with regard to agricultural income is concerned, section 10(5) of the Act specifically points out that agricultural income shall not be included in computing the total income ... required to be considered at all even for the purpose of section 11 of the Act.” 9.7 While deciding the question that the agricultural income was income from the property held under the trust can be denied exemption u/s 11 of the Income Tax Act. the Hon’ble High Court

Hiteshbhai Rameshbhai Patel, Surat vs. ITO Ward, 2, Bardoli

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

ITA 484/SRT/2025[2012-13]Status: DisposedITAT Surat23 Dec 2025AY 2012-13

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2012-13 Hiteshbhai Rameshbhai Patel Income Tax Officer, 466 Kanbivad, Goddha Mahuwa, Ward-2, Bardoli, Income Tax Taluka Valod, Dist. Surat 394630 Vs. Office, 2Nd Floor, Bsnl Gujarat, Building, Opp. Jalaram Temple, Station Road, Bardoli- 394601 Pan No. Avdpp 6788 Q Appellant Respondent Assessee By : Mr. Sakar Sharma, Ar Revenue By : Mr. J.K. Chandani, Sr-Dr

For Appellant: Mr. Sakar Sharma, ARFor Respondent: Mr. J.K. Chandani, Sr-DR

Section 143(3)Section 147Section 148Section 151(1)Section 68

without appreciating that entire deposit of cash was nothing but redeposit of cash withdrawn on earlier occasions and also on account of earning of agricultural income.” 2. Briefly stated, the facts of the case are that the Assessing Officer received information through the Income-tax Portal that during the financial ... were issued calling upon the assessee to furnish details of the bank account, cash deposits made therein, particulars of agricultural land held, details of agricultural income claimed, and expenses incurred for earning such income. 2.3 Upon consideration of the submissions and material placed on record, the Assessing Officer completed

Nasim Ahmad Khan, Siddharthnagar vs. ACIT, Gonda- New

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

ITA 492/LKW/2024[2017-18]Status: DisposedITAT Lucknow23 Dec 2025AY 2017-18

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.492/Lkw/2024 ननिाारण वर्ा/ Assessment Year: 2017-18 Nasim Ahmad Khan V. The Asstt. Ward No.7, Subhash Nagar, Commissioner Of Income Shohratgarh, Siddharthnagar, Tax, Uttar Pradesh-272205. Gonda New 271003. Pan:Aigpk3776M अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: None प्रत्यर्थी कक और से /Respondent By: Shri R. R. N. Shukla, Addl. Cit(Dr) सुनवाई कक तारीख / Date Of Hearing: 26 11 2025 घोर्णा कक तारीख/ Date Of 23 12 2025 Pronouncement: आदेश / O R D E R

For Appellant: NoneFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 143(2)Section 68

rise to the present appeal are that the assessee filed his return of income declaring a total income of Rs.54,51,340/- along with agricultural income of Rs.3,50,000/-. Thereafter, the case was selected for limited scrutiny, the reason for such selection being examination of share capital/capital contribution. Accordingly

Rahulkumar Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

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

ITA 1770/MUM/2025[2023-24]Status: DisposedITAT Mumbai23 Dec 2025AY 2023-24

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana, Addl. CIT

Section 11Section 12ASection 139(1)Section 143(1)Section 250

Rahulkumar Bajaj Charitable Trust provisions of sub-sections (2) and (3). Sub section (2) of section 2 speaks of an assessee having net agricultural income exceeding five thousand rupees, in addition to total income, hence, is not relevant for our purpose. However, sub section (3) of section 2 of Finance

Rahulkumar Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

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

ITA 1769/MUM/2025[2022-23]Status: DisposedITAT Mumbai23 Dec 2025AY 2022-23

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana, Addl. CIT

Section 11Section 12ASection 139(1)Section 143(1)Section 250

Rahulkumar Bajaj Charitable Trust, Mumbai vs. Deputy Commissioner of Income Tax, Mumbai

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

ITA 1768/MUM/2025[2021-22]Status: DisposedITAT Mumbai23 Dec 2025AY 2021-22

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Shri R. R. Makwana, Addl. CIT

Section 11Section 12ASection 139(1)Section 143(1)Section 250

Kaithi Govardhan Reddy (HUF), Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

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

ITA 1189/HYD/2025[2020-21]Status: DisposedITAT Hyderabad19 Dec 2025AY 2020-21

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1189/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Shri Kaithi Govardhan Vs. Income Tax Officer Reddy ( Huf ) Ward 7 (1) Hyderabad Hyderabad Pan:Aahhk3441C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Snsr Chinmai, Advocate राज" व "ारा/Revenue By:: Shri T. Venkanna, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 15/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri SNSR Chinmai, AdvocateFor Respondent: : Shri T. Venkanna, Sr. DR

case are that the assessee is a HUF, which filed its return of income for the Assessment Year 2020-21 on 10.03.2021, declaring agricultural income of Rs.50,00,000/-. The case of the assessee was selected for scrutiny to verify the large claim of agricultural income. During the assessment proceedings ... assessee submitted that it had earned agricultural income of only Rs.5,00,000/- during the year under consideration, however, due to a clerical mistake, instead of Rs.5,00,000/-, the figure of Rs.50,00,000/- was mentioned in the return of income. During the assessment proceedings, the Learned Assessing Officer

Shweta Gaday, Bidar vs. Income Tax Officer, Ward-1, Bidar

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

ITA 2314/BANG/2024[2015-16]Status: DisposedITAT Bangalore19 Dec 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2015-16

For Appellant: Shri Subramanya Bhat, CAFor Respondent: Shri Subramanian .S, JCIT-DR

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

equity.” 2. The brief facts of the case are that the assessee filed her return of income declaring an income from other sources and agricultural income and claimed the said income as exempt. The AO based on the cash deposits made into her savings bank account maintained with

Shri Jasbir Singh Sahni, Bathinda vs. Income Tax Officer Ward-1, Bathinda

The appeal stands allowed for statistical purposes

ITA 45/ASR/2025[2012-13]Status: DisposedITAT Amritsar18 Dec 2025AY 2012-13

Bench: Tribunal.

For Appellant: Shri Salil Chopra (Advocate) – Ld. ARFor Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR

Section 144

assessment has been framed on best judgment basis wherein Ld. AO made addition of cash deposit of Rs.7,90,500/- and also considered the agricultural income of Rs.2,10,000/- as income from other sources since the assessee failed to make any representation therein

Shri Ramnikbhai Jasarajbhai Patel, at. Dhrangadhra, Dist. Surendranagar vs. The ITO Ward-3, Surendranagar

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

ITA 244/RJT/2023[2013-14]Status: DisposedITAT Rajkot18 Dec 2025AY 2013-14

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Rupesh Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 144Section 148

agricultural and appellant family having land around 100 bighas and cultivating crop of Fruits, seeds, vegetables and Raw Cotton various documents in support of agricultural income on sale proceeds of Fruits and Raw Cotton deposited and made withdrawal in agricultural loan account with Saurastra Gramin Bank treated as undisclosed source

Mangamma Chirumamilla, Guntur vs. Income Tax Officer, Ward 2(1), Guntur

In the result, appeal of the assessee is dismissed

ITA 151/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam18 Dec 2025AY 2018-19

Bench: SHRI SANDEEP SINGH KARHAIL, HON’BLE (Judicial Member), SHRI OMKARESHWAR CHIDARA, HON’BLE (Accountant Member)

Section 142(1)Section 144Section 147Section 148Section 148A

source of cash deposit of Rs.10,00,000/- is concerned, it was claimed that she has got an agricultural land and was deriving agricultural income, out of which, cash of Rs.10,00,000/- was deposited in the bank account. It was also mentioned in the written submission, that ... treated as capital gain, without reducing the cost of purchase of the same immovable property. The Ld.AO should have considered about past savings and agricultural income before making the addition of cash deposits of Rs.10,00,000/-. It was mentioned before the Ld.CIT(A) that the notices issued u/s 148A

Pravinsinh Bhawansinh Vaghela, Gandhinagar vs. The Income Tax Officer, Ward-3, Gandhinagar

In the result, appeal of the assessee is partly allowed

ITA 829/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad18 Dec 2025AY 2012-13

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Parimalsinh B. Parmar, ARFor Respondent: Shri B. P. Srivastava, Sr. DR

Section 143(3)Section 54BSection 54FSection 68

whether it was used for agricultural purposes during the two years preceding the date of transfer. After considering Form No. 12, 7/12 extracts, agricultural income declared by the assessee, and other documentary evidence, the CIT(Appeals) held that the land was indeed agricultural land and was used for agricultural purposes

Thakarshi Maharaj, Anjar Kutch vs. ITO, Ward-2, Gandhidham

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

ITA 820/RJT/2024[2012-13]Status: DisposedITAT Rajkot17 Dec 2025AY 2012-13

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 820/Rjt/2024 (िनधा"रणवष"/Assessment Year: (2012-13) Thakarshi Maharaj Income Tax Officer, Ward – 2, Chandrani, Anjar, Kutch-370 020 (Guj) Vs. Gandhidham, Aayakar Bhavan, Sector-8, Gandhidham – 370 201 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bllpm 3616 D (अपीलाथ"/Assessee) (""थ"/Respondent) Assessee By : Shri Mehul Ranpura, Ar Respondent By : Shri Abhimanyu Singh Yadav, Sr. Dr

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR

Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 250

officer. On perusal of submission, it was observed by the assessing officer that the assessee has shown interest income of Rs.1,56,993/- and agricultural income of Rs.13,07,106/-. On perusal of submission and details, the assessing officer noticed that assessee had sold an agricultural land bearing survey number ... source of cash deposit during the year under consideration stating that it was out of earlier savings and cash withdrawal from bank and agricultural income and opening cash balance. In response, the assessee also furnished reply letter dated. 11.12.2019, before the assessing officer. 7. However, assessing officer rejected the above

Shrivardhan Biotech Private Limited, Kondigre vs. Income Tax Office, Ichalkaranji

In the result, the appeal of assessee is treated as allowed for statistical purpose

ITA 2191/PUN/2025[2018-19]Status: DisposedITAT Pune17 Dec 2025AY 2018-19

Bench: Shri Rama Kanta Panda, Vice- & Ms. Astha Chandra

For Appellant: Shri Pramod S ShingteFor Respondent: Smt. Indira R. Adakil, Addl.CIT

Section 143(1)Section 143(2)Section 143(3)Section 249(2)

agricultural produce cultivated in its farm. For AY 2018-19, assessee filed its return of income on 31/10/2018 declaring income of ₹ NIL and agricultural income of ₹ 2,07,56,730/-. The return was initially processed u/s. 143(1) of the Income Tax Act, 1961 (“Act”). Subsequently, case of the assessee

Chinnakannu Sundhar, Ponneri vs. ITO, Ncw-10(3), Chennai

In the result, the appeal of the assessee is allowed for statistical purposes and the Stay application is dismissed as infructuous

ITA 3190/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Dec 2025AY 2018-19

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3190/Chny/2025 & S.A No.124/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19 Chinnakkannu Sundhar, The Income Tax Officer, Peruncherry, Vs. Non Corporate Ward-10(3), Panchetty, Ponneri-600 052. Chennai. Pan: Eyrps 6145H

For Appellant: Ms. S. Deepika, AdvocateFor Respondent: Ms. Babitha, JCIT

Section 148Section 2(14)Section 250

assessee in response, filed the return of income on 21.03.2023 admitting total income of Rs. 2,07,510/- and agricultural income of Rs.90,000/-. The assessee submitted before the A.O that the immovable property sold is an agricultural land and the entire proceeds are reinvested towards purchase of agricultural land

M T Krishne Gowda, Hassan vs. Income Tax Officer, Ward-1 & Tps, Hassan

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

ITA 832/BANG/2025[2020-21]Status: DisposedITAT Bangalore17 Dec 2025AY 2020-21

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2020-21 Shri. M. T. Krishne Gowda, Vs. Ito, Lakshmi Stone Crushing Industries, Ward – 1& Tps, Muduganur Arkalgud, Hassan. Hassan – 573 201, Karnataka. Pan : Arupk 5347 F Appellant Respondent Assessee By : Shri. Mahesh R Uppin, Ar Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 17.12.2025

For Appellant: Shri. Mahesh R Uppin, ARFor Respondent: Shri. Balusamy N, JCIT(DR)(ITAT), Bangalore

Section 115BSection 68

Briefly stated facts of the case are that assessee filed return of income on 31.03.2021 declaring income of Rs.53,54,810/- and exempted agricultural income of Rs.95,15,000/-. The case was selected for scrutiny and statutory notices were issued to the assessee. In the notice, various details were asked ... details and documents of land, bank accounts, Page 2 of 5 computation of income but failed to furnish any documentary evidence with respect to agricultural income shown. Assessee furnished failed to furnish documentary evidence with respect to sale of produce, crops cultivated, expenses made on purchase of seeds, any bill/invoices

Amninder Singh, Pathankot vs. Income Tax Officer, Ward-1, Pathankot

The appeal stands allowed for statistical purposes

ITA 321/ASR/2025[2020-21]Status: DisposedITAT Amritsar16 Dec 2025AY 2020-21

Bench: Tribunal. The Ld. Sr. Dr Pleaded For Dismissal Of The Appeal.

For Appellant: Adj. Letter dated 15-12-2025For Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR

Section 144

best judgment basis u/s 144 r.w.s. 144B of the Act on 26-09-2022. In the assessment order Ld. AO made addition of agricultural income for Rs.44.80 Lacs. The Ld. CIT(A) did not admit the appeal for want of condonation of delay of 97 days. Aggrieved, the assessee

Shri Kamleshkumar Vallabhbhai Chanchdia, Village Sardhar, Dist. Rajkot vs. The ITO-Ward-2(1)(2), Rajkot

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

ITA 156/RJT/2021[2016-17]Status: DisposedITAT Rajkot16 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri S. N. Divetia, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

sale of agricultural produce or any land holding Page 2 of 4 ITA No. 156/RIT/2021 Kamleshkumar V. Chanchdla documents, the claim of assessee regarding agricultural income cannot be accepted. Therefore, the same is being added as unexplained cash credits u/s 68 of the Act r.w.s. 11SBBE

Manish Ishwarbahi Patel, Vadodara vs. ITO, Ward 3(1)(4), Vadodara

ITA 1829/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad16 Dec 2025AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinha

Section 115BSection 143(3)Section 68

declaring Nil income. The case was selected for scrutiny under CASS. The Assessing Officer noticed that the assessee had disclosed agricultural income of Rs.51,43,825/-. In the course of assessment, the Assessing Officer had made enquiries in this regard but was not satisfied with the genuineness of the agricultural ... income as disclosed. Accordingly, the entire agricultural income of Rs.51,43,825/- was treated as unexplained and added to the income. The assessment was completed under Section 143(3) of the Act on 21.09.2022 at a total income of Rs.51,43,825/-. 3. Aggrieved with the order of the Assessing

Belathur Srinivasaiyengar Rangaiyengar, Mysore vs. Income Tax Officer, Ward-1(1), Mysore

In the result, appeal of the assessee is allowed

ITA 574/BANG/2025[2017-18]Status: DisposedITAT Bangalore16 Dec 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Sri Lokanath S., A.RFor Respondent: Sri Balusamy N., D.R

Section 143(2)Section 143(3)Section 250Section 269SSection 44A

income. On verification of the details furnished during the course of assessment proceedings, it was noticed by the AO that the assessee had claimed agricultural income to the tune of Rs.46,57,720/-. Further, the AO observed that under column 4 of schedule-“EI”, the assessee had shown both ... gross receipts and the net agricultural income for the year at Rs.46,57,720/- only. No expenditure had been shown towards the accrual of agricultural income. The AO was of the opinion that it is very difficult to conduct agricultural activity without any expenditure as the agricultural activities are very