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“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
98
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
98
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

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT (Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as under:

ITA 349/LKW/2025[2016-17]Status: DisposedITAT Lucknow11 Dec 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 132Section 253(3)

estimation made by VO and Hon’ble ITAT Lucknow Bench has rejected the appeal of Revenue. Issue No. 7 – AY 2020-21 Disallowances of Agriculture Income in tune of Rs. 37,00,000/- That in the relevant assessee and his family earned agricultural income in tune ... Further, during the course of assessment proceedings detail of agricultural income was submitted as under:- 1. That as regard to gross agriculture income of Rs.52 Lacs earned by assessee along with his family members, it is relevant to mention, relevant year while filing of ITR, assessee has incorporated inadvertently agricultural

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT (Central)-2, Lucknow

ITA 348/LKW/2025[2015-16]Status: DisposedITAT Lucknow11 Dec 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 145(3)Section 54FSection 69

addition of Rs. 37,00,000/- out of total addition of Rs.52,00,000/- made u/s 69A of the Act on account of treating agricultural income as unexplained income without looking into the facts and circumstances of the case. The addition of Rs.37,00,000/- which is made on adhoc ... account of addition u/s 69A without appreciating the fact that the assessee was unable to correlate the cash found with the agricultural income shown. 3. Whether on facts and circumstances of the case and in law, the CIT(A) has erred in deleting the addition of Rs.35

Rakesh Kumar Pandey, Gonda vs. DCIT/ACIT, (Central)-2, Lucknow

In the result, the outcome of the appeals and Cross Objections are as

ITA 347/LKW/2025[2014-15]Status: DisposedITAT Lucknow11 Dec 2025AY 2014-15

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 40A(3)Section 69

total addition of Rs, 52,00,000/- made u/s 69A of the Act on account of treating agricultural income as unexplained money without looking into the facts and circumstances of the case. The addition of Rs, 37,00,000/- which is made on adhoc & estimated basis, is also liable ... account of addition u/s 69A without appreciating the fact that the assessee was unable to correlate the cash found with the agricultural income shown. . Whether on facts and circumstances of the case and in law, the CIT(A) has erred in deleting the addition

Sidhesh Mohan Raikar, Nashik vs. Deputy Director of Income Tax, Centralized Processing Centre, Banglore

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

ITA 294/PUN/2025[2023-24]Status: DisposedITAT Pune11 Dec 2025AY 2023-24

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.294/Pun/2025 Assessment Year : 2023-24

For Appellant: Shri Devendra JainFor Respondent: Shri Pramod Shahkar
Section 143(1)Section 154Section 199Section 5A

37BA Sl.No. Particulars Amount 01 Total receipts offered to tax under various heads 45,28,441 (Including receipts under Schedule E1 other than the Agricultural income part) in the return 02 Total receipts as per Form 26AS from various 2,33,06,642 deductors (amounts appearing against TCS and 194N ... Raikar Sl.No. Particulars Amount 01 Total receipts offered to tax under 45,28,441/- various heads (including receipts under Schedule E1 other than the Agricultural income part) in the return 02 Total receipts as per Form 26AS from 2,33,06,642 various deductors (amounts appearing against TCS and 194N

Mohammad Saidullah, East Champaran vs. ITO, Ward- 1 (3), Motihari

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

ITA 245/PAT/2025[2017-18]Status: DisposedITAT Patna10 Dec 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 250Section 56(2)(x)Section 68

facts. 2. For that the learned Addl. CIT(A) should have asked for further clarification/evidences before confirming the additions/disallowances. 3. For that the agricultural income of Rs. 1,23,255/- received from sale of paddy through PAX and payment received through banking channels should not have been disbelieved and addition ... were received through banking channels and bank statement of donor were filed during course of hearing. 5. For that the donor is having only agricultural income and was not obliged to file ITR. The identity, genuineness and creditworthiness of the donor are proved beyond doubt from the submission and copy

Gurminder Singh, Ambala City vs. Income Tax Officer Ward-2, Ambala, Ambala Cantt

The appeal stand allowed

ITA 887/CHANDI/2025[2024-25]Status: DisposedITAT Chandigarh10 Dec 2025AY 2024-25

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.887/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2024-25) Sh. Gurminder Singh Ito Ward-2 बनाम/ Vs. H.No.1998, Sec.9, Urban Estate Ambala 133001 Ambala City – 134003 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Cidps-7267-J (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Gurminder Singh (Assessee-In-Person) ""थ"कीओरसे/Respondent By : Smt. Moatenla (Jcit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 17-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Sole Grievance Of The Assessee In Captioned Appeal For Assessment Year (Ay) 2024-25 Is Quantum Of Rebate U/S 87A. The Impugned Order Has Been Passed By Learned Addl. / Joint Commissioner Of Income Tax (Appeals)-1, Nagpur [Cit(A)] On 27-05- 2025 In The Matter Of An Intimation Issued By Cpc U/S 143(1) On 23-03- 2025. Having Heard Rival Submissions, The Appeal Is Disposed-Off As Under.

For Appellant: Shri Gurminder Singh (Assessee-in-person)For Respondent: Smt. Moatenla (JCIT) – Ld. Sr. DR
Section 112A(6)Section 143(1)Section 87ASection 9

Capital Gains 2,247/- 4. Debt Short Term Capital Gains 7,607/- 5. Income from other sources 3,13,177/- Total 5,45,315/- Agricultural Income (for rate purposes) 8,47,263/- Against computed tax of Rs.27,586/-, the assessee claimed rebate u/s 87A for Rs.25,000/- and tax payable

Ilyasbhai Kasambhai Rathod, Chhotaudepur vs. The ITO, Ward-3(1)(4) (Previously Ward-3(1)(5)), Vadodara

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

ITA 1311/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad10 Dec 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 142(1)Section 143(2)Section 143(3)Section 144Section 44ASection 69A

assessee has not provided any documentary evidence in this regard and the claim of the assessee was disallowed. Further, the assessee had also shown agricultural income of Rs.7,67,698/-. The assessee was asked to furnish the details alongwith documentary evidences in this regard. However, the assessee has not complied ... with any of the statutory notices issued by the Assessing Officer. Hence, agricultural income shown by the assessee to the tune of Rs.7,67,698/- was treated as unexplained income from undisclosed sources under Section 69A of the Act. The assessment was completed under Section 144 read with Section

Siva Sankara Reddy Tunga, Hyderabad vs. ITO., Ward - 14(1), Hyderabad

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 1060/HYD/2025[2016-17]Status: DisposedITAT Hyderabad10 Dec 2025AY 2016-17

Bench: Us:

Section 147Section 148Section 148ASection 69A

under Section 69A merely on conjectures and surmises without properly appreciating the assessee's explanation supported by bank statements agricultural income certificate in the name of the spouse and details of salary withdrawals and without bringing any contrary material. b) The Ld. CIT(A) failed to consider the agricultural income

Classic Bio-Tech Exports Limited, Bangalore vs. ITO., Ward-1(1), Hyderabad

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

ITA 1362/HYD/2024[2018-19]Status: DisposedITAT Hyderabad10 Dec 2025AY 2018-19

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON’BLE (Accountant Member)

Section 69C

domestic company engaged in agricultural activities, filed its return of income for A.Y. 2018-19 on 28.03.2019, declaring total income nil and net agricultural income of Rs. 39,42,060/-. The case was selected for scrutiny and during the course of assessment proceedings, the A.O. noticed that, the assessee ... agricultural receipts of Rs. 72,84,186/- and whereas the expenditure incurred on agricultural activities was at Rs. 33,42,126/- before reporting net agricultural income of Rs. 39,42,060/-. The A.O. called upon the assessee to file relevant evidences, including landholding details, details of agricultural operations carried

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

return of Income for AY 2017-18 was filed on 06/12/2017 declaring total taxable Income of Rs 11,670/- along with exempt net agricultural income of Rs 24,35,777/-. 6. The case of the assessee was selected under CASS limited security, and accordingly, notice ... dated 16/08/2018 was issued to examine 'Agricultural Income' along with Questionnaire to furnish Page 2 of 9 ITA No. 2726/DEL/2024 [A.Y. 2017-18] Maroon Organic Farming Vs. ITO relevant details and documents pertaining to possession of agricultural land and agricultural income. 7. The assessee replied to the said notice alongwith

Shri Padamraj Singh Darri, Bemetara vs. Income Tax Officer, Ward-Kawardha, Kawardha

In the result, the appeal of the assessee is allowed

ITA 734/RPR/2025[2016-17]Status: DisposedITAT Raipur09 Dec 2025AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.734/Rpr/2025 िनधा"रण वष" /Assessment Year: 2016-17 Shri Padamraj Singh, Darri, Hatranka, Bemetara, 491338, Chhattisgarh. Pan: Ckapb0951P .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: None (Adjournment Application)For Respondent: Dr. Priyanka Patel, Sr.DR
Section 68Section 694

assessee. In fact, the revenue accepts that the assessee is a farmer and his earning from agricultural activities. Therefore, having savings from such agricultural income cannot to be doubted in the hands of the assessee without any evidence on record placed by the revenue. The Department has also not stated

Usha Yadav, Lucknow vs. Income Tax Officer Range 6(2), Lucknow

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 251/LKW/2024[2013-14]Status: DisposedITAT Lucknow09 Dec 2025AY 2013-14

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Shri Dharmendra Kumar, CAFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)
Section 10(37)Section 139(1)Section 144Section 147Section 148Section 2(14)(iii)Section 271(1)(c)

years. Her husband Sri Babulal Yadav died on 17-12-1994, She brought up her children solely with small amount of family pension, agricultural income and honorarium from Anganwadi’. Her total income was below the maximum amount chargeable to income-tax, hence she did not file her return of income ... years. Her husband Late Babulal Yadav died on 17-12-1994. She brought up her children solely with small amount of family pension, agricultural income and honorarium from ‘Anganwadi’. ITA. Nos. 249 & 251/LKW/2024 Page 8 of 13 b. As noted in para-2 and para-3 above, agricultural land purchased

Usha Yadav, Lucknow vs. Income Tax Officer Range 6(2), Lucknow

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 249/LKW/2024[2013-14]Status: DisposedITAT Lucknow09 Dec 2025AY 2013-14

Bench: Shri Kul Bharat & Shri Nikhil Choudhary

For Appellant: Shri Dharmendra Kumar, CAFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)
Section 10(37)Section 139(1)Section 144Section 147Section 148Section 2(14)(iii)Section 271(1)(c)

years. Her husband Sri Babulal Yadav died on 17-12-1994, She brought up her children solely with small amount of family pension, agricultural income and honorarium from Anganwadi’. Her total income was below the maximum amount chargeable to income-tax, hence she did not file her return of income ... years. Her husband Late Babulal Yadav died on 17-12-1994. She brought up her children solely with small amount of family pension, agricultural income and honorarium from ‘Anganwadi’. ITA. Nos. 249 & 251/LKW/2024 Page 8 of 13 b. As noted in para-2 and para-3 above, agricultural land purchased

Parvatbhai Baria, Gujarat vs. ITO, Ward 1, Godhra, Gujarat

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

ITA 1583/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2018-19

Bench: Ms Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./Ita No. 1583/Ahd/2025 िनधा"रण वष"/Asstt. Year: 2018-2019 Parvatbhai Baria, The Income Tax Officer, बनामVs. 818, Vavdi Gam, Ward-1, Dahod Highway, Godhra. Vavdi Buzurg, Panchmahal-389001. Gujarat.

For Appellant: Shri Abbas Gulamhusianwala, ARFor Respondent: Shri Saresh Kartik Laxmanbhai, Sr. DR
Section 139(1)Section 142(1)Section 147Section 148Section 153CSection 250(6)Section 270ASection 45

dated 29.03.2022. In response, the assessee filed a return of income on 02.03.2024 declaring total income at Rs. Nil and agricultural income of Rs. 1,81,500/-. The Assessing Officer issued statutory notices under section 142(1) of the Act. The assessee submitted his reply dated 03.03.2023, stating that

Vikas Maruti Nalawade, Sangli vs. Income Tax Officer, Sangli

In the result, appeal of the assessee is partly allowed

ITA 737/PUN/2025[2017-18]Status: DisposedITAT Pune09 Dec 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं./Ita No. 737/Pun/2025 धििेंारण वर्ा /Assessment Year: 2017-18 Vikas Maruti Nalawade, Ito, Ward-1, Sangli Vikas Hitech Nursary, Sangli Islampur Road, Near Sootgirni Vs. Tung, Sangli-416301 Maharashtra Pan-Alppn6432M अपीलेंर्थी / Appellant प्रत्यर्थी / Respondent Assessee By: Shri Pramod S Shingte Department By: Shri Amit Bobde-Cit Date Of Hearing: 09-12-2025 Date Of Pronouncement: 16-12-2025 आदीश /Order Per Dr. Manish Borad:- This Appeal At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A) Nfac, Delhi Passed U/S 250 Of The Income-Tax Act, 1961 Dated 05.03.2025 Which Is Arising Out Of Assessment Order Passed U/S 147 R.W.S. 144B Of The Act Dated 29.03.2022. 2. Assessee Has Raised Following Grounds Of Appeal:- 1. On The Facts & Circumstances Of The Case & In Law, The 2 Assessment Order, Having Being Passed Without Following The Principles Of Natural Justice, As Narrated In The Statement Of Facts, The Same Is Bad In Law & Hence Needs To Be Quashed.

For Appellant: Shri Pramod S ShingteFor Respondent: Shri Amit Bobde-CIT
Section 147Section 148Section 250Section 69A

addition of Rs. 10,445 being 8% of the gross contracting receipts of Rs. 1,30,551 even though the same formed part of agricultural income of the appellant. The appellant prays that the AO be directed to delete the addition. The appellant craves leave to add to, amend, alter ... return in compliance to the notice u/s 148 of the Act declaring total taxable income at Rs. 7,960/- and 3 also declared exempt Agricultural income at Rs. 1,54,54,912/- In the course of the reassessment proceedings various details called for by the Ld. AO were furnished based

Greatwall Marketing Pvt Ltd, Delhi vs. ACIT Central Circle-30, New Delhi

In the result, appeal of assessee in ITA No

ITA 4158/DEL/2025[2012-13]Status: DisposedITAT Delhi09 Dec 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Mohit Chaudhary, AdvFor Respondent: Shri Manish Gupta, Sr. DR
Section 115BSection 143(3)Section 148Section 153CSection 68

case are that the assessee is a private limited company and engaged in the business as trader in commodities, besides earning interest income and agricultural income, as depicted in the audited accounts. The assessee filed its return for AY 2012-13 of 29.09.2012 declaring nil income. Further a further return

Salek Chand Saini, Meerut vs. ITO, Ward-2(3), Meerut

In the result, appeal of assessee in ITA No

ITA 2545/DEL/2024[2014-15]Status: DisposedITAT Delhi09 Dec 2025AY 2014-15

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Rohit Aggarwal, CAFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 143(3)Section 68

their respective affidavits filed before them. 11. The remaining amount of Rs.2,42,000/- has been deposited by the assessee out of the agricultural income earned by him during the year and out of the sale proceeds of trees grown on the agricultural land sold by the appellant. Reliance

Shashi Kumar Mehta, Sonipat vs. ITO Ward 4, Sonipat

In the result, appeal of assessee in ITA No

ITA 2135/DEL/2024[2017-18]Status: DisposedITAT Delhi09 Dec 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Ms. Rano Jain, AdvFor Respondent: Shri Manish Gupta, Sr. DR
Section 143(2)Section 40A(3)Section 68

assessee e-filed his return of income for the A.Y under consideration on 17.03.2018, declaring an income of Rs. 3,14,160/- plus agricultural income of Rs. 2,00,000/-. The case of the assessee was selected for scrutiny Page 2 of 7 ITA No. 2135/DEL/2024 [A.Y 2017-18] Shashi

Shree Vikas Sharafi Sahkari Mandli Limited, Rajkot vs. PCIT-1 Rajkot, Rajkot

In the result, the appeal of the assessee is allowed

ITA 228/RJT/2025[2020-21]Status: DisposedITAT Rajkot08 Dec 2025AY 2020-21

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

For Appellant: Shri Chetan Agarwal, Ld. A.RFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)
Section 147Section 2(19)Section 263Section 80(2)(f)Section 80PSection 80P(2)(a)Section 80P(2)(d)Section 80P(2)(f)

scrutiny through CASS for the following reasons: 1. High value cash deposits reported in SFT(Business cases). 2. Low income (including exempt income and agricultural income) in comparison to high loans/ advances/ Investment in shares appearing in balance sheet. 3. High liabilities as compared to low income/receipts. 4. Chapter

Nandkumar Baban Saste, Pune vs. ITO, Ward 8(3), Pune

In the result, appeal of the Assessee is allowed for

ITA 99/PUN/2025[2017-18]Status: DisposedITAT Pune08 Dec 2025AY 2017-18

Bench: Dr. Manish Borad & Shri Vinay Bhamore

For Respondent: Shri Bharat Andhale, Addl.CIT
Section 143(2)Section 147Section 148Section 250Section 270A

written submissions filed, assessee claimed that he is a farmer and has no other income other than agricultural income. He submitted that assessee made declaration under IDS, 2016 in ignorance of law and misrepresentation made by his advisor. It is stated that ITA.No.99/PUN./ 2025 (Nandkumar Baban Saste) assessee declaration