“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

Ashwinkumar Shankarlal Patel (HUF), Ahmedabad vs. ITO, Ward 6(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 2558/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad16 Mar 2026AY 2017-18

Bench: Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Shri Sunil Maloo, A.RFor Respondent: Smt. Mamta Singh, Sr. D.R

Section 145(3)Section 69A

That, the Ld. CIT(A) has falled to consider that in the show cause notice issued by the Ld. AO, agricultural income of Rs. 5,49,456/- was accepted and explanation was sought only for Rs. 6,10,544/-, whereas the addition of the entire amount ... assessee’s case was selected for limited scrutiny for large value of cash deposit during demonetization period and large agricultural income shown in ITR. The Assessing Officer issued statutory notices for which the assessee filed details of agricultural income along with sale bills agricultural produce, copy of 7/12 extracts, bank

Akhilesh Mishra, Nanakmatta vs. Income Tax Officer, Khatima

In the result, the appeal of the assessee is allowed

ITA 31/DDN/2026[2014-2015]Status: DisposedITAT Dehradun13 Mar 2026AY 2014-2015

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal[Assessment Year : 2014-15] Akhilesh Mishra Vs Ito Sitarganj Road, Near Balaji Mandi Samiti Mandir, Nanakmatta Campus, Khatima, Sahib, Sitarganj, Udham Singh Uttarakhand -262311 Nagar, Pan-Awkpm6776B Uttarakhand Appellant Respondent Appellant By Shri Amit Kumar Mishra, Ca Respondent By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 11.03.2026 Date Of Pronouncement 13.03.2026 Order Per Bench: The Present Appeal Is Filed By Assessee Against The Order Dated 19.09.2025 Passed By Ld. Commissioner Of Income Tax (A), Nfac, Delhi [“Ld.Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 28.11.2019 Passed U/S 144 R.W.S. 148 Of The Act Pertaining To Assessment Year 2014-15. 2. Brief Facts Of The Case Are That The Assessee Is A Teacher & Having Source Of Income From Private Teaching/Tuition. The Return Of Income Was Filed Declaring Total Income At Inr 3,60,140/-. The Case Of The Assessee Was Selected For Scrutiny & Order Was Passed U/S 148 R.W.S.144 Of The Act Dated 28.11.2019 By Making Addition Of Inr 29,15,000/- Towards The Cash Deposit As Unexplained Income Of The Assessee.

Section 144Section 148Section 250

record. It is an admitted fact that assessee is a well-qualified teacher of Hindi and Sanskrit subjects and besides this is having agricultural income from agricultural land which was regularly declared in the return of income filed for several years. Assessee also filed copies of capital account for various

ITO, Ward-1(1)(3), Dehradun vs. Trishla Steel Pvt Ltd, Dehradun

In the result, the appeal filed by the Revenue is dismissed

ITA 188/DDN/2025[2017-18]Status: DisposedITAT Dehradun13 Mar 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S. Rifaur Rahman

Section 143(2)Section 68

proceeded to make the addition under the head “capital gain” to the extent of Rs. 2,13,16,178/-. Further, the assessee has claimed agricultural income earned during the year. The Ld. AO observed that the assessee has not claimed any expenditure for earning the agricultural income, it clearly shows ... account of sale of agricultural land under the head Long Term Capital gain. Hence this ground of appeal is allowed.” 7. With regard to agricultural income, ld. CIT(A) deleted the same observing as under: “8.3 [have examined the reply dated 27.12.2019 of the appellant which is at page number

Navdeep Singh, New Delhi vs. DCIT Circle - 13, Gurgaon

In the result, the appeal of the assessee ITA No

ITA 401/DEL/2021[2015-16]Status: DisposedITAT Delhi13 Mar 2026AY 2015-16

Bench: Shri Satbeer Singh Godara, Hon’Ble & Shri Naveen Chandra, Hon’Ble

Section 143(2)Section 143(3)Section 234ASection 250(6)Section 40Section 68

father along with the details of land held by him and argued that his father is agriculturist and the said amount is accumulation of agricultural income. The AO, however, rejected the explanation and therefore, he made the addition as unexplained credit ... find from the assessment order that the assessee’s father had 18 acres of land from where the assessee claimed to have procured agricultural income. We further find that the assessee has also furnished the bank statement of his father. The AO has dismissed the explanation on the ground that

Kunwar Pranav Singh Champion, Roorkee vs. Income Tax Officer, Roorkee

In the result, the captioned appeals of the assessee in ITA No

ITA 41/DDN/2026[2020-21]Status: DisposedITAT Dehradun12 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 250Section 271ASection 68

account of unexplained cash credit which was sustained for the reason that assessee has failed to file the details with respect to the agricultural income declared by him. Even before AO, no such details were filed by the assessee. Thus, considering these facts and in the interest of justice ... matter is restored to the file of AO with the direction to examine the agricultural income declared by the assessee. The assessee is directed to file all the necessary evidences in support of the agricultural income declared. With these directions, all grounds raised by the assessee in ITA No.40/DDN/2026

Kunwar Pranav Singh Champion, Roorkee vs. Income Tax Officer, Roorkee

In the result, the captioned appeals of the assessee in ITA No

ITA 40/DDN/2026[2020-21]Status: DisposedITAT Dehradun12 Mar 2026AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 143(3)Section 250Section 271ASection 68

Mahesh Kenchanagundu, Nandyala vs. ITO., Ward-1, Nandyal

ITA 1611/HYD/2025[2015-14]Status: DisposedITAT Hyderabad11 Mar 2026AY 2015-14

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita.No.1611/Hyd/2025

Section 147Section 269SSection 271DSection 273B

facts and in law. • That the penalty under Section 271D is not maintainable as the appellant accepted loans in cash from agriculturists who have agricultural income only and are covered under the exception as per proviso to Section 269SS. • That sufficient evidence was filed establishing the identity and agricultural income

Seenaiah Boddupalli, Hyderabad vs. DCIT., Central Circle 2(4), Hyderabad

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

ITA 1168/HYD/2025[2020-21]Status: DisposedITAT Hyderabad11 Mar 2026AY 2020-21

Bench: him which are proper documents and crucial evidence for disposing the appeal in favour of the appellant.

Section 131Section 142(1)Section 250

assessee calling for return of income. The assessee filed his return of income on 29.06.2021 admitting total income of Rs. 67,255/- and agricultural income at Rs. 2,72,565/-. During the course of assessment proceedings, the assessee neither personally appeared nor furnished any details. Therefore, a final show-cause

Lakshmanappa Parameshwarappa Prakash, Chikkamagaluru vs. ACIT, Hassan

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

ITA 2271/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Roshan Manssor, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 142(1)Section 250Section 68

assessee submitted that he, along with his mother, was engaged in agricultural activities. It was explained that the assessee’s mother had been earning agricultural income over a long period of time and had accumulated cash from such activities. After the announcement of demonetisation, the mother handed over the cash ... period. 4.1 However, the Assessing Officer did not accept the explanation of the assessee. According to the Assessing Officer, there was no mention of agricultural income in the return of income of the assessee or any of his family members. In the absence of supporting evidence, the . ITA No.2271 /Bang/2025

Sakalaspur Veerappiah Rudrappa Coffee Planter Harakanahally Estate, Ballupet vs. Income Tax Officer, Ward-2, Hassan

In the result, the appeal of the assessee is allowed

ITA 2200/BANG/2025[2017-18]Status: DisposedITAT Bangalore11 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250Section 69

response to the notices issued by the AO, the assessee submitted that its primary source of income was from coffee plantation which constitutes agricultural income and is exempt from tax under the Act. It was further submitted that the agricultural produce was sold to traders and agents and the receipts ... appreciate the nature of the assessee’s activity. The assessee is a coffee planter and the receipts from the sale of coffee beans constitute agricultural income which is exempt under the provisions of the Act. It was submitted that in plantation activities, agricultural produce is frequently sold to traders

Sartaj Ahmad, Sitapur vs. The DCIT/ACIT (Central Circle-2), Lucknow

In the result, the grounds of appeal as well as the appeal of the assessee allowed

ITA 617/LKW/2025[2023-24]Status: DisposedITAT Lucknow10 Mar 2026AY 2023-24

Bench: Shri Kul Bharat & Shri Anadee Nath Misshraassessment Year: 2023-24 Sartaj Ahmad V. The Dcit/Acit (Central Village & Post: Rambhari, Circle)-2 Biswan, Sitapur-261201 (Up). Income Tax Office, Lucknow, Uttar Pradesh. Pan:Acxpa4335P (Appellant) (Respondent) Appellant By: Shri Mahendra Kumar, Fca Respondent By: Shri R. R. N. Shukla, Addl. Cit(Dr) O R D E R

For Appellant: Shri Mahendra Kumar, FCAFor Respondent: Shri R. R. N. Shukla, Addl. CIT(DR)

Section 132Section 143(3)

large family who stay together in joint system of living. The appellant assessee has submitted that the cash in consideration belong to agriculture income of various family members. The same was from excerpted from Q-61 of the statement given by the appellant during the search proceedings. It is also ... their claim of cash along with their confirmations. In most of the cases the family members were under the scrutiny and in some cases agricultural income and cash-in-hand was accepted by the AO. The person wise claims and their acceptability is discussed as per below

Mukesh Kumar HUF, Ambala vs. Income Tax Officer-Ward-3, Yamuna Nagar

In the result, appeal of the assessee is allowed

ITA 1189/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh09 Mar 2026AY 2020-21

Bench: Disposal Of The Appeal.

For Appellant: Shri Dhruv Goel, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR

Section 115BSection 69A

That learned CIT(A) NFAC has erred in law and facts in confirming the action of AO in estimating agriculture Income of 25,50,000/-. 4. That the appellant craves leave to add, alter, and amend or to substitute the above grounds of appeal before disposal of the appeal ... assessee, a Hindu Undivided Family, filed its return declaring agricultural income of Rs.42,50,000/- and other income of Rs.3,500/-. The case was selected for limited scrutiny to examine large agricultural income per acre. During assessment proceedings, the Assessing Officer noticed that the assessee had shown nil agricultural expenses

Satya Pal Daryani, Jabalpur vs. Income Tax Office Ward 2(2), Jabalpur

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

ITA 92/JAB/2025[2015-16]Status: DisposedITAT Jabalpur06 Mar 2026AY 2015-16

Bench: Shri Anadee Nath Misshra

Section 143(3)

whereby the assessee’s total income was determined at Rs.23,07,600/- as against returned income of Rs.3,07,600 and Rs.24,83,347/- (Agricultural income). The assessee’s appeal against the assessment order was dismissed by the Ld. CIT(A) vide impugned appellate order dated 20.02.2025. This present appeal

Kamlesh Koushal, Indore vs. Income Tax Officer, 1(2), Indore

In the result, the impugned order is set aside as & by way of

ITA 708/IND/2025[2017-18]Status: DisposedITAT Indore06 Mar 2026AY 2017-18

Bench: Shri B.M. Biyani & Shriparesh M Joshi

Section 133(6)Section 142(1)Section 144Section 246ASection 250Section 253Section 272A(1)(d)Section 274Section 69A

concluded by the AO. During the submission filed in appellate stage, the assessee submitted that the only source of income of the appellant was agricultural income, which is exempt in nature. In the absence of any cogent reason backed by sufficient evidence, the explanation of the appellant is only ... Page 15 of 18 Kamlesh Koushal ITA No. 708/Ind/2025 - A.Y.2017-18 dt. 31.05.2019 wherein the total income as ROI is Rs. 1991/-. Net agricultural income is Rs. 4,05,650/-. Our attention was invited to page 17 of the PB to demonstrate that a reply dt. 21.08.2019 was filed before

Debpara Tea Co. Ltd., Kolkata vs. PCIT, Siliguri

In the result, the appeal of the assessee is allowed

ITA 983/KOL/2025[2020-2021]Status: DisposedITAT Kolkata06 Mar 2026AY 2020-2021

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 143(3)Section 263Section 8

Income Tax Rules, 1962 whereby 40% of income shall be treated as taxable income and remaining 60% shall be treated as agricultural income which is exempt from taxation. The Ld. PCIT noted that during the year the net profit from business was Rs. 85,42,565/- and accordingly net profit ... types of income: a) Tea growing & Manufacturing Business Income Rs. (1,95,74,644/-) b) Trading Business Income Rs. 3,18,838 c) Purely Agricultural Income Rs. 2,74,52,602/- (other than Tea manufacturing) d) Interest Income Rs. 1,65,769/- e) Rental Income Rs. 1,80,000/- Total

Rameshkumar Kandasamy, Tiruppur vs. ITO, Ward-2(1), Tiruppur

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

ITA 3257/CHNY/2025[2018-19]Status: DisposedITAT Chennai06 Mar 2026AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 3257/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Shri Ramesh Kandasamy, The Income Tax Officer, 627/1, Hallmark Knit Fabs, Vs. Ward 2 (1), Rakkiyapalayam, Tiruppur Kangeyam Road, Tiruppur – 641 606. Pan: Ahhpr 4639J (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms.S.P. Sri Harini, Advocate ""यथ" क" ओर से/Respondent By : Shri A.T. Krishnamoorthy, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 05.03.2026 घोषणा क" तारीख/Date Of Pronouncement : 06.03.2026 आदेश/ O R D E R Per George George K: This Appeal Filed By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 02.09.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2018-19. :- 2 -: 2. At The Very Outset, We Notice That The Order Passed By The First Appellate Authority (Faa) Is Ex-Parte, Since There Was No Compliance From The Assessee To Five Notices Issued From The Office Of The First Appellate Authority.

For Appellant: Ms.S.P. Sri Harini, AdvocateFor Respondent: Shri A.T. Krishnamoorthy, Addl.CIT

Section 143(3)Section 250Section 68

Knit Fabs’. For the assessment year 2018-19, assessee filed his return of income declaring total income Rs.13,70,490/- after claiming exemption of agricultural income of Rs.56,40,500/-. The return was selected for limited scrutiny. During the course of assessment proceedings, assessee was directed to submit the details/evidences ... with regard to the claim of agricultural income. In response the assessee submitted written submissions along with details of agricultural income. However, the AO completed the assessment u/s.143(3)of the Act vide order dated 12.03.2021 assessing the total income at Rs.53,52,020/- after making addition of agricultural income

Chanda Bharech Beneficiary Trust, Kolkata vs. ITO, Ward 33(2), Kolkata

In the result, the appeals of the assessee are allowed

ITA 3062/KOL/2025[2022-2023]Status: DisposedITAT Kolkata05 Mar 2026AY 2022-2023

Bench: The Bench That The Issue Is Squarely Covered By The Special Bench Of The Mumbai In The Case Of Araadhya Jain Trust Vs. Ito, Ita No. 4272/Mum/2024, A.Y. 2023-24, Order Dated 09.04.2025, Wherein A Similar Issue Has Been Decided In Favour Of The Assessee. The Ld. Ar Therefore, Prayed That The Issue May Be Kindly To Be Decided In The Light Of Said Decision By Following The Same As The Facts Are Similar.

Section 143(1)Section 164Section 167BSection 2Section 250

subject to the provisions of sub-sections (2) and (3). Sub sec- tion (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

Chanda Bharech Beneficiary Trust, Kolkata vs. ITO, Ward 33(2), Kolkata

In the result, the appeals of the assessee are allowed

ITA 3061/KOL/2025[2021-2022]Status: DisposedITAT Kolkata05 Mar 2026AY 2021-2022

Section 143(1)Section 164Section 167BSection 2Section 250

Chanda Bharech Beneficiary Trust, Kolkata vs. ITO, Ward 33(2), Kolkata

ITA 3060/KOL/2025[2020-2021]Status: DisposedITAT Kolkata05 Mar 2026AY 2020-2021

Section 143(1)Section 164Section 167BSection 2Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, KOLKATA SHRI RAJESH KUMAR, ACCOUNTANT MEMBER Ι.Τ.Α. Nos. 3060-3062

Mamatha Mahesh Shetty, Chikkamagaluru vs. Income Tax Officer, Ward-1, Chikmagalur

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

ITA 2382/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: Shri Ravishankar S.V, AdvocateFor Respondent: Shri Ganesh R Ghale, Advocate – Standing

Section 250

receipt and payment account. The same not disclosed in her return of income filed under section 148 of the Act under the impression of agricultural income being exempted from income tax. 10.4 However, the AO did not accept the explanation furnished by the assessee. The AO found that the assessee ... such type of crop, extent of land used for particular crop, yield, expenses incurred, gross receipt and mode of receipt etc. in support of agricultural income. The AO also observed that as per the earlier submission of the assessee, the property in the year under consideration was purchased