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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

Ramendra Singh, Kannauj vs. Income Tax Officer Ward 4(2)(3), Kannauj

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

ITA 53/ALLD/2025[2017-18]Status: DisposedITAT Allahabad21 Nov 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Ramendra Singh V. The Income Tax Officer Bahadurpur Ward 4(2)(3) Majhigawan Kannauj Kannauj (U.P) Tan/Pan:Gzqps7971P (Appellant) (Respondent) Appellant By: Shri Shvetank Garg, Advocate Respondent By: Shri A. K. Singh, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 26.07.2023, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That Huge Amounts Have Been Credited To The Assessee’S Bank Account No.001311002103008 Maintained With Farrukhabad District Central Co-Operative Bank, Saurikh, Kannauj By Way Of Cash & Credit Entries. The Assessing Officer (Ao) Issued Notice Under Section 142(1) Of The Income Tax Act, 1961 (Hereinafter Called “The Act’), Requiring The Assessee To Furnish The Return Of Income For The Year Under Consideration. However, The Said Notice Was

For Appellant: Shri Shvetank Garg, AdvocateFor Respondent: Shri A. K. Singh, D.R
Section 115BSection 142Section 142(1)Section 144Section 69ASection 80T

receipts were Rs.38,41,698/- And all cash withdrawal & Payments were Rs.10,27,000/- thus there was Net taxable Income 92,199/- in Expected & Agricultural Income 72,910/- Thus there was no other Income which from mandatory taxability creating for filing ITR. 3. Section 144/142(1) (ex-Parte assessment order

Rameshbhai Popatbhai Dakhra Legal Heir of Popatbhai Virabhai Dakhra, Surat vs. ITO, Ward 2(3)(3), Surat

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

ITA 170/SRT/2025[NA]Status: DisposedITAT Surat21 Nov 2025

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.170/Srt/2025 Assessment Year: 2017-18 (Physical Hearing) Rameshbhai Popatbhai Dakhra Income Tax Officer Ward-2(3)(3), बनाम/ Legal Heir Of Popatbhai Surat, Aayakar Bhavan, Surat-395 Vs. Virabhai Dakhra 001 Plot No.17,Ganesh Row House, Nr. Shyamdham Temple, Sarthana, Jakatnaka, Surat- 395 006 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aknpd 3920 H (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Mehul Shah, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 01/09/2025 उद्घोषणा की तारीख/Date Of Pronouncement 21/11/2025

Section 143(2)Section 144Section 250Section 69A

learned CIT(A) has erred in confirming the action of Assessing Office in making addition of Rs.14,97,000/- by considering the exempt agriculture income as income from other sources. 6. It is therefore prayed that the addition made by Assessing Officer and confirmed by the learned ... case are that the assessee filed the return of income for AY 2017-18 on 06.03.2018 declaring total income at Rs.25,200/- and agricultural income of Rs.14,97,000/-. The case of the assessee was selected for scrutiny under CASS. During assessment proceedings, notices u/s 143(2) ITA No.170/Srt/2025

Ch Veerraju Co, Rajahmundry vs. DCIT, Circle-1, Rajahmundry

The appeal of the assessee is partly allowed in terms of our aforesaid observations

ITA 561/VIZ/2025[2018-19]Status: DisposedITAT Visakhapatnam21 Nov 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.561/Viz/2025 (निर्धारण वर्ा/Assessment Year: 2018-19) Ch. Veerraju & Co, Vs. Deputy Commissioner Of Rajahmundry. Income Tax, Pan: Aacfc8959Q Circle-1, Rajahmundry. (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Smt. A. Aruna, Advocate रधजस्‍व द्वधरध/Revenue By: Dr. Aparna Villuri, Sr. Ar सुिवधई की तधरीख/Date Of 18/11/2025 Hearing: घोर्णध की तधरीख/Date Of 21/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm : The Present Appeal Filed By The Assessee Firm Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 26/08/2025 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) R.W.S143(3A) & 143(3B) Of The Income-Tax Act, 1961 (For Short, “The Act”), Dated 15/04/2021 For The Assessment Year 2018-19. The 2 Ch Veerraju & Co Vs. Dcit

For Appellant: Smt. A. Aruna, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 143(3)

justified in sustaining the addition of Rs. 22,67,968/- made by the Assessing Officer by treating the agricultural income as income from other sources.” 2. Succinctly stated, the assessee firm which is engaged in the business of quarry and crusher maintenance had e-filed its return of income ... fact. 3. During the course of the assessment proceedings, the AO observed that the assessee firm had disclosed in its Profit & Loss Account agricultural income of Rs. 22,67,968/-. On being called upon to substantiate its aforesaid claim of income based on supporting documentary evidence, viz., nature and type

George Thomas, Kottayam vs. Income Tax Officer Ward 1 Kottayam, Kottayam

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

ITA 808/COCH/2025[2020-21]Status: DisposedITAT Cochin21 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2020-21 George Thomas .......... Appellant Kurissummoottil Mukkalli, Parathodu Edakkunnam, Kottayam 686512 [Pan: Afypt6697M] Vs. The Income Tax Officer, Ward-1, Kottayam .......... Respondent Assessee By: Shri Prasanth Srinivas Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 19.08.2025 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Deriving Agricultural Income. The Return Of Income For Ay 2020-21 Was Filed On 05.01.2021 Declaring Nil Income Showing Agricultural Income Of Rs. 26,00,000/-. Against The Said Return Of Income, The Assessment Was Completed By The Assessment Unit Of Income Tax Department (Hereinafter Called "The Ao") Vide Order Dated 23.09.2022 Passed U/S. 144 R.W.S. 144B Of The Act At Total Income Of 2 George Thomas Rs. 32,00,000/-. While Doing So, The Ao Brought To Tax The Entire Receipts Shown From Agriculture Of Rs. 32,00,000/- For The Failure Of The Appellant To Discharge The Onus Of Proving He Agricultural Income.

For Appellant: Shri Prasanth SrinivasFor Respondent: Smt. Leena Lal, Sr. D.R
Section 144

dated 19.08.2025 for Assessment Year (AY) 2020-21. 2. Brief facts of the case are that the appellant is an individual deriving agricultural income. The return of income for AY 2020-21 was filed on 05.01.2021 declaring Nil income showing agricultural income of Rs. 26,00,000/-. Against the said ... entire receipts shown from agriculture of Rs. 32,00,000/- for the failure of the appellant to discharge the onus of proving he agricultural income. 3. Being aggrieved, an appeal was filed before the CIT(A) with a delay of 774 days. The CIT(A) dismissed the appeal without condoning

Anthony Louis, Ernakulam vs. ITO, Non Corp Ward 2(5) Kochi, Kochi

In the result, the appeal filed by the assessee stands dismissed

ITA 751/COCH/2025[2020-21]Status: DisposedITAT Cochin21 Nov 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am Assessment Year: 2020-21 Anthony Louis .......... Appellant 40/2096A, B Peevas Triton Marine Drive Kochi 682031 [Pan: Acppl0790F] Vs. Ito, Non Corporae Ward - 2(5), Kochi .......... Respondent Assessee By: Shri Stephen George, Ar Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 06.11.2025 Date Of Pronouncement: 21.11.2025 O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 21.08.2025 For Assessment Year (Ay) 2020-21. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Deriving Income From Agriculture. The Return Of Income For Ay 2020-21 Was Filed On 09.01.2021 Disclosing Nil Income & Declaring Agricultural Income Of Rs. 64,80,620/-. Against The Said Return Of Income, The Assessment Was Completed By The Assessment Unit Of Income Tax Department (Hereinafter Called "The Ao") Vide Order Dated 21.09.2022 Passed U/S. 143(3) R.W.S. 144B Of The Income

For Appellant: Shri Stephen George, ARFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(3)

individual deriving income from agriculture. The return of income for AY 2020-21 was filed on 09.01.2021 disclosing Nil income and declaring agricultural income of Rs. 64,80,620/-. Against the said return of income, the assessment was completed by the Assessment Unit of Income Tax Department (hereinafter called

Nirmala Thomas, Gudalur vs. ITO, Ward-1, Ooty

In the result, the appeal of the assessee is allowed

ITA 672/CHNY/2025[2022-23]Status: DisposedITAT Chennai21 Nov 2025AY 2022-23

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.672/Chny/2025 Assessment Years: 2022-23 Nirmala Thomas Income Tax Officer, No.12/342-A G.V.Estate, Ward-1, Thorapalli, Gudalur, Ooty. Tamil Nadu-643 212 [Pan: Aetpt3435K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri S.Girish Kumar, Advocate प्रत्यर्थी की ओर से /Revenue By : Ms.Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 19.09.2025 घोषणा की तारीख /Date Of Pronouncement : 21.11.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri S.Girish Kumar, AdvocateFor Respondent: Ms.Gouthami Manivasagam, JCIT
Section 56

Authority. The Ld.Counsel for the assessee took us through brief factual matrix of this case. The case was selected to verify the genuineness of agricultural income disclosed by the assessee. It was noted that the agricultural income disclosed during the year was at variance with figures of preceding years ... assessee had shown total agricultural receipts of Rs.1,95,99,538/- and expenditure of Rs.1,14,61,979/- so as to offer net exempt agricultural income of Rs.81,37,559/-. The Ld.AO observed that there are total credits of Rs.2,90,03,302/- in the bank accounts maintained

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

In the result, both the appeals filed by the Revenue and the

ITA 1235/CHNY/2025[2015-16]Status: DisposedITAT Chennai21 Nov 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- Industries Pvt Ltd Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

Section 132Section 143(1)Section 143(2)Section 14ASection 153CSection 250Section 80G

tribunal has found that with regard to cash and jewellery, the explanation of the assessee was that he had agricultural properties and derived agricultural income. That income was utilised to acquire jewellery that was belonging to him and his family. With regard to cash and stated to be recovered from

Southern Agrifurane Industries Pvt. Ltd., Chennai vs. ACIT, Central Circle-2(2), Chennai

ITA 1233/CHNY/2025[2014-15]Status: DisposedITAT Chennai21 Nov 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- Industries Pvt Ltd Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

Section 132Section 143(1)Section 143(2)Section 14ASection 153CSection 250Section 80G

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक