“ agricultural income ”

CIT v. Punjab State Cooperative Agricultural Development Bank Ltd.

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.

389 ITR 68 · 2016 · High Court

192

Mavilayi Service Co-operative Bank Ltd. v. CIT

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.

414 ITR 67 · 2019 · High Court

190

Smt. Harshila Chordia v. ITO

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.

298 ITR 349 · 2008 · High Court

187

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

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.

154 Taxmann.com 305 · 2023 · Supreme Court

136

CIT v. Raja Benoy Kumar Sahas Roy

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.

32 ITR 466 · 1957 · Supreme Court

132

Sabarkhanta Zilla Kharid Vechan Sangh Ltd. v. ClT

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.

203 ITR 1027 · 1993 · Supreme Court

CIT v. Usha Stud Agricultural Farms Ltd.

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.

301 ITR 384 · 2008 · High Court

ITA 1215/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh01 Dec 2025AY 2018-19

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

Prakash Chand, Shimla vs. Income Tax Officer, Shimla

The appeal stand allowed

Bench: us.3. The Ld. AR has placed on record computation of agricultural income. It could be seen that the assessee has earned gross agricultural income of Rs.86.01 Lacs and incurred various expenditure on account of labor charges, salary, packing charges, fertilizers & chemicals and finally, computed agricultural income of Rs.47.30 Lacs. The transaction-wise detail along with source of payment has also been furnished. In its reply to Ld. CIT(A) on 04-09-2024, the assessee had furnished details of

For Appellant: Sh. Vishal Mohan (Sr. Advocate) with Sh. PraveenFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR

Section 143(3)Section 69C

Rs.38.70 Lacs. Having heard rival submissions and upon perusal of case records, the appeal is disposed-off as under. 2. The assessee earns agricultural income from apple orchards. It claims that approx. 40% to 45% of sales from agricultural produce is expended towards this activity. However, the assessee could ... addition was confirmed against which the assessee is in further appeal before us. 3. The Ld. AR has placed on record computation of agricultural income. It could be seen that the assessee has earned gross agricultural income of Rs.86.01 Lacs and incurred various expenditure on account of labor charges, salary

Syed Mohamed Sathik Ali, Dindigul vs. ITO, Ward-1(3), Dindigul

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

ITA 2362/CHNY/2025[2017-18]Status: DisposedITAT Chennai01 Dec 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2362/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Syed Mohamed Sathik Ali, Vs. The Income Tax Officer, C/O Shri T.N. Seetharaman, Advocate, Ward 1(3), # 384 (Old No. 196), Lloyds Road, Dindigul. Chennai 600 086. [Pan: Ajdps6560R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T.N. Seetharaman, Advocate ""थ" की ओर से/Respondent By : Ms. M. Subashri, Addl. Cit (Virtual) सुनवाई की तारीख/ Date Of Hearing : 20.11.2025 घोषणा की तारीख /Date Of Pronouncement : 01.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By The Addl/Jcit(A)-1, Nashik For The Assessment Year 2017-18. 2. The Assessee Raised 5 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made As Income From Capital Gains

For Appellant: Shri T.N. Seetharaman, AdvocateFor Respondent: Ms. M. Subashri, Addl. CIT (Virtual)

Section 143(3)

whether the ld. CIT(A) is justified in confirming the addition made as income from capital gains 2 I.T.A. No.2362/Chny/25 denying the claim of agricultural income in the facts and circumstances of the case. 3. We note that the Assessing Officer completed the assessment order under section ... assessee at ₹.17,86,320/- against the returned income at ₹.5,77,800/-, after making disallowance of ₹.12,08,520/- claimed as agricultural income out of sale from cutting of the oak trees and added to the income returned by the assessee under the head Income from Capital Gains

Ashish Mansukhlal Gokani, Mithapur vs. Commissioner of Income Tax (Appeals), Delhi

In the result, appeal filed by the assessee is allowed

ITA 483/RJT/2025[2013-14]Status: DisposedITAT Rajkot28 Nov 2025AY 2013-14

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.483/Rjt/2025 िनधा"रण वष"/Assessment Year : 2013-14 बनाम Ashish Mansukhlal Gokani Commissioner Of Income Tax Mithapur, Dist: Devbhoomi, (Appeals), / Dwarka (Guj) – 361345 National Faceless Assessment Vs [Mahesh N. Paun Advocate, Centre (Nfac), Income Tax Taxation Consultant, Shreeji Department, Delhi Chambers, 17-Nava Para, Near S.B.I. (Adb), Jam-Khambhaliya, Gujarat – 361305] "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aappg2259N (अपीलाथ"/Appellant) (""थ"/Respondent)

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

Section 139Section 147Section 148Section 151Section 250(6)Section 271BSection 68

brief details of the assessee are mentioned above. The assessee filed return of income on 30/12/2014, declaring total income Rs. 1,85,850/- and agricultural income of Rs. 2,48,610/-for A. Y. 2013-14. As per information available on records, the asssesssee has carried out significant financial transactions ... details of escapement of income: In this case, the assessee filed return of income on 30/12/2014, declaring total income Rs. 1,85,850/- and agricultural income of Rs: 2,48,610/-for A. Y. 2013-14. On perusal of report of ADIT(Inv.), Jamnagar available at INSIGHT Portal

Tejaskumar Subhashbhai Patel, Surat vs. Income Tax Officer, Ward 2(2)(1), Surat

ITA 340/SRT/2024[2017-18]Status: DisposedITAT Surat28 Nov 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha, J

Section 144Section 254(1)

well as law on the subject, the learned CIT(A) has erred in confirming the actions of the Assessing Officer in treating the agricultural income of Rs.42,68,517/- as income from other source. 2. It is therefore prayed that the addition made by Assessing Officer and confirmed ... relatives and power of attorney given by his relatives. The assessee filed revised computation of total income at Rs.18,94,712/- as agricultural income. The AO added total income of Rs.1,45,81,437/- as undisclosed sources income of assessee. 6. Aggrieved by the order of the AO, the assessee

Tejaskumar Subhashbhai Patel, Surat vs. Income Tax Officer, Ward 2(2)(4), Surat

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

ITA 339/SRT/2024[2015-16]Status: DisposedITAT Surat28 Nov 2025AY 2015-16

Section 144Section 254(1)

Sri Sahasralingeswara Swamy Temple, Guntur vs. Income Tax Officer (Exemption Ward), Guntur

The appeals of the assessee are allowed mutatis mutandis for the A

ITA 489/VIZ/2024[2013-14]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2013-14

Bench: The Tribunal, The Assessee Filed Appeals (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter In Short “Ld.Cit(A)”] Vide Respective Din & Order No. As Stated Below: -

ITA 339/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2016-17

Considering the submissions of the assessee, Ld. CIT(A) granted partial relief to the extent of Rs. 11,53,325/- which was declared as Agricultural Income, thereby reduced the taxable income of the assessee to Rs. 5,65,990/-. 6. Aggrieved by the order of the Ld. CIT(A), assessee

Sri Sahasralingeswara Swamy, Ponnur vs. Income Tax Officer, Exemptions Ward, Guntur

The appeals of the assessee are allowed mutatis mutandis for the A

Bench: The Tribunal, The Assessee Filed Appeals (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter In Short “Ld.Cit(A)”] Vide Respective Din & Order No. As Stated Below: -

ITA 338/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2015-16

Sri Sahasralingeswara Swamy Temple, Ponnur vs. Income Tax Officer, Exemptions Ward, Guntur

The appeals of the assessee are allowed mutatis mutandis for the A

Bench: The Tribunal, The Assessee Filed Appeals (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter In Short “Ld.Cit(A)”] Vide Respective Din & Order No. As Stated Below: -

ITA 337/VIZ/2024[2014-15]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2014-15

Sri Sahasralingeswara Swamy Temple, Ponnur vs. Income Tax Officer, Exemptions Ward, Guntur

The appeals of the assessee are allowed mutatis mutandis for the A

Bench: The Tribunal, The Assessee Filed Appeals (Appeals), National Faceless Appeal Centre, Delhi [Hereinafter In Short “Ld.Cit(A)”] Vide Respective Din & Order No. As Stated Below: -

ITA 121/VIZ/2024[2015-16]Status: DisposedITAT Visakhapatnam28 Nov 2025AY 2015-16

Paila Venkata Padmavathi, Visakhapatnam vs. Income Tax Officer, Ward-5(3), Visakhapatnam

In the result, appeal of the assessee is dismissed

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.121/Viz/2024 (निर्धारण वर्ा/ Assessment Year:2015-16) Vs. Paila Venkata Padmavathi The Income Tax Officer Ward– 5(3) 3-47, Thanam Aayakar Bhavan Paravada Mandal Dabagardens, Visakhapatnam Paravada – 531021 Andhra Pradesh Andhra Pradesh [Pan: Bsipp1954P]

Section 131Section 143(1)Section 143(2)Section 143(3)Section 156Section 282(1)

accepting and allowing Rs. 71 lacs approx. (sale proceeds of spouse) and calling for evidence of balance cash deposits in Bank. Even otherwise the agricultural income is exempted u/s 10(1) and producing bills falls squarely in "Doctrine of Impossibility." A case of Bonafide nature since assessee or spouse ... assessee were in belief that being agricultural income was not taxable at all. 6. Taxability in wrong hands: The Ld. AO has not justified in assessing the income in the hands of assessee instead of initiating assessment on the spouse of the assessee when Ld AO came to know

Akash Jain, Bhopal vs. DCIT (Central-1), Bhopal

Appeal is allowed

ITA 333/IND/2025[2018-19]Status: DisposedITAT Indore28 Nov 2025AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshiakash Jain, Dcit (Central-1) बनाम/ B-244, Shahpura, Bhopal Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Assessees By Shri S.S. Deshpande, Ar Revenue By Shri Ashish Porwal, Sr. Dr

Section 132Section 139Section 143(3)Section 153ASection 271ASection 80CSection 80T

which the assessee filed original return u/s 139 on 30.08.2018 declaring a total income of Rs. 3,10,230/- alongwith exempted agricultural income of Rs. 11,793/-. While completing assessment u/s 143(3), the AO made two adjustments, namely (i) Deduction of Rs. 1,60,000/- claimed by assessee under ... Chapter-VIA was disallowed, and (ii) Exempted agricultural income was not accepted partly to the extent of Rs. 2,948/- and addition was made. This way, the AO assessed total income at Rs. 4,73,178/- (r/o to Rs. 4,73,180/-). Simultaneously, the AO initiated proceeding for imposition

Jagir Kaur, Chandigarh vs. Income Tax Officer, Ward - 5(5), Chandigarh

In the result, appeal of the Assessee is allowed

ITA 951/CHANDI/2025[2013-14 ]Status: DisposedITAT Chandigarh28 Nov 2025

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 142(1)Section 147Section 148

bank account which is arbitrary and illegal 4. That the assessee had complete sources of cash deposit in the bank account being receipts from agricultural income and lease rentals in the shape of sale proceeds of wheat and millet duly explained during the course of assessment and appellate proceedings ... assessee nor her representative 3 produced any tangible evidence to prove that agricultural operations were carried out or that the cash deposits represented genuine agricultural income. The AO noted that mere submission of an affidavit was insufficient to establish the conduct of agricultural activities or the source of the cash

Daulat Savala Narute, Pune vs. ITO Ward 5(20, Pune

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

ITA 520/PUN/2025[2015-16]Status: DisposedITAT Pune28 Nov 2025AY 2015-16

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.520/Pun/2025 Assessment Year : 2015-16

For Respondent: Shri Udol Raj Singh

Section 147

Best Judgment Assessment and even in the appeal filed before ld.CIT(A) assessee has raised only one ground that the assessee earns only Agricultural income which is exempt from tax and all cash deposits are from Agricultural income. However, assessee failed to appear before ld.CIT(A) and the ld.CIT

Dr Pamod Eknathrao Jadhav, Aurangabad vs. ITO, Ward-1(6), Aurangabad

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

ITA 2381/PUN/2025[2017-18]Status: DisposedITAT Pune28 Nov 2025AY 2017-18

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2381/Pun/2025 िनधा"रण वष" / Assessment Year : 2017-18 Dr. Pramod Eknathrao Vs. Ito, Ward-1(6), Jadhav, Aurangabad. Row House No.1, Samarth Heritage, Opp. Marathwada Sanskrity Mandal Khadkeshwar, Aurangabad- 431001. Pan : Adfpj4882K Appellant Respondent Assessee By : Shri Pratikh Jha Revenue By : Shri Umesh Phade Date Of Hearing : 26.11.2025 Date Of Pronouncement : 28.11.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.06.2025 Passed By Ld. Addl./Jcit(A)-1, Gurugram [‘Ld. Cit(A)’] For The Assessment Year 2017-18. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied

For Appellant: Shri Pratikh JhaFor Respondent: Shri Umesh Phade

Section 10(1)Section 143(2)Section 143(3)Section 250Section 69A

Appeals) [CIT(A)] u/s 250 of the Income Tax Act, 1961 is bad in law, contrary to facts, and liable to be quashed. 2. Agricultural Income: The Learned CIT(A) has erred in confirming the addition of ₹5,34,045/- made by the Assessing Officer by rejecting the claim ... agricultural income u/s 10(1) of the Act for want of 7/12 extract, despite the appellant having submitted (a) lease agreement for agricultural land taken on "theka" basis, (b) sale pattis of green chillies, and (c) confirmation from the land owner, Smt. Sindhubai Bhaskar Pagare. The addition made on mere

Savita Mitkari, Pune vs. Income Tax Officer, Pune

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

ITA 2193/PUN/2025[2011-12]Status: DisposedITAT Pune28 Nov 2025AY 2011-12

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2193/Pun/2025 निर्धारण वर्ष / Assessment Year: 2011-12 Savita Mitkari, V The Income Tax Officer, Flat No.302, G4, Gangadham S Pmt Phase Ii, Market Yard, Building Pune 411037. Commercial Complex, Swargate, Pune 411037. Pan: Arppm8052L Appellant/ Assessee Respondent / Revenue Assessee By Ca Sagar Kale Shri Arvind Renge – Addl.Cit(Dr) Revenue By Date Of Hearing 06/11/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal) [Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2011-12 Dated 30.07.2025 Emanating From The Assessment Order Passed Under Section 143(3) R.W.S 147 Of The Act, Dated 30.12.2018. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 147Section 250Section 68

appellant is an individual taxpayer engaged in agricultural activities. For Assessment Year (AY) 2011-12, the appellant filed her Income Tax Return disclosing agricultural income and other sources of income. The case was subsequently reopened under Section 147 of the Income Tax Act, 1961 and reassessed under Section ... considered by the CITA) That the addition of 7,35,000 as unexplained cash deposits is wholly erroneous, as the same pertains to legitimate agricultural income supported by: Proper agricultural sale invoices showing sale of produce during the relevant financial year. The appellant's Income Tax Return

Deputy Commissioner of Income-Tax, Bengaluru vs. Mathikere Ramaiah Seetharam, Bengaluru

In the result, the appeal of the assessee is allowed

ITA 1297/BANG/2025[2020-21]Status: DisposedITAT Bangalore28 Nov 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Rahul Chaudhary

For Appellant: Shri H.N Khincha, CAFor Respondent: Shri Muthu Shankar, CIT (DR)

ITA 1296/BANG/2025[2021-22]Status: DisposedITAT Bangalore28 Nov 2025AY 2021-22

wherein department accepted the returned income of the assessee at Rs.1,85,34,040/- under head Business Income and Rs.1 lakh from agricultural income. The date of search in the case of M/s. Ramaiah Developers & Builders Pvt. Ltd. was on 23.8.2016 and the assessment . ITA Nos.1027-1028-1296-1297-1286/Bang/2025 Page

Deputy Commissioner of Income-Tax, Bengaluru vs. Mathikere Ramaiah Seetharam, Bengaluru

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Rahul Chaudhary

For Appellant: Shri H.N Khincha, CAFor Respondent: Shri Muthu Shankar, CIT (DR)

ITA 1286/BANG/2025[2020-21]Status: DisposedITAT Bangalore28 Nov 2025AY 2020-21

Mathikere Ramaiah Seetharam, Mathikere vs. ACIT, Circle-1(2), Bangalore

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Rahul Chaudhary

For Appellant: Shri H.N Khincha, CAFor Respondent: Shri Muthu Shankar, CIT (DR)

ITA 1099/BANG/2025[2014-15]Status: DisposedITAT Bangalore28 Nov 2025AY 2014-15

Chowdadenahalli Rangaswamy Manohara, Bangalore vs. DCIT, Central Circle-2(1), Bangalore

In the result, appeal filed by the assessee is dismissed

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyassessment Year : 2014-15 Shri. Chowdadenahally Rangaswamy Manohar, Vs. Dcit, No.88/89, M C Halli, Chikka Tirupati Road, Central Circle – 2(1), Sarjapura, Anekal Taluk, Bangalore. Bangalore – 562 125. Pan : Ajzpm 9900 D Appellant Respondent Assessee By : Shri. Tirumala Naidu, Ar Revenue By : Shri. Shivanand H Kalakeri, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 19.11.2025 Date Of Pronouncement : 28.11.2025

For Appellant: Shri. Tirumala Naidu, ARFor Respondent: Shri. Shivanand H Kalakeri, CIT(DR)(ITAT), Bangalore

Section 132Section 139Section 139(1)Section 143(3)Section 153ASection 37

search conducted on 15.03.2016, an assessment came to be completed under section 143(3) r.w.s. 153A on 29.12.2017, wherein additions were made towards agricultural income, self-made vouchers, and disallowance under section 37. Subsequently, on 03.01.2019, a fresh search under section 132 was conducted. Consequent thereto, the case was centralized

DCIT, CC-2(1), Bengaluru vs. Mathikere Ramaiah Seetharam, Bengaluru

In the result, the appeal of the assessee is allowed

ITA 1028/BANG/2025[2017-18]Status: DisposedITAT Bangalore28 Nov 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Rahul Chaudhary

For Appellant: Shri H.N Khincha, CAFor Respondent: Shri Muthu Shankar, CIT (DR)