“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

Kangayam Chennpalanisamy, Coimbatore vs. Income-Tax Officer, Corporate Ward 2, Coimbatore

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

ITA 1606/CHNY/2025[2017-18]Status: DisposedITAT Chennai11 Nov 2025AY 2017-18

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1606/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Kangayam Chennpalanisamy, Vs. The Income Tax Officer, No. 78, Cheran Towers, Arts College Corporate Ward 2, Road, Coimbatore 641 018. Coimbatore. [Pan:Afepp8162K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Shreyansh Kumar Kochar, C.A. ""थ" की ओर से/Respondent By : Shri C. Sivakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 21.08.2025 घोषणा की तारीख /Date Of Pronouncement : 11.11.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 6 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Disallowance Made By The Assessing Officer On Account Of Agricultural Income.

For Appellant: Shri Shreyansh Kumar Kochar, C.AFor Respondent: Shri C. Sivakumar, Addl. CIT

consideration as to whether the ld. CIT(A) is justified in confirming the disallowance made by the Assessing Officer on account of agricultural income. 2 I.T.A. No.1606/Chny/25 3. It is noted that the assessee claimed agricultural income to the tune of ₹.71,06,500/- and in order to verify ... approximately aggregating to total 10 acres of agricultural land vide patta and not for non-production of any receipt nor invoice in support of agricultural income and expenses, disallowed the said claim by treating the same as non-agricultural income. The ld. CIT(A) vide para 6 of the impugned

Raas Intratech Private Limited, Delhi vs. ITO, Delhi

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

ITA 3497/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Nov 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Sh. Sudhir Kumar

Section 143(3)

brief facts of the case are that assessee had claimed income of Rs. 26,17,065/- as exempt being in the nature of agricultural income. During the assessment proceedings, appellant was asked to submit the details of this exempt income, but no details were submitted before the AO. Accordingly, such ... assessee be accorded an opportunity to represent its case before CIT(A) for adjudication of issues disputed under this appeal in respect of agricultural income and demonetization period. 6. The Ld. Departmental representative (DR) could not controvert the aforesaid proposition of the Ld. AR, but he however, relied upon

Anuja Rajesh Bajaj, Chennai vs. ITO, Corporate Ward-1(2), Chennai

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

ITA 2240/CHNY/2025[2010-11]Status: DisposedITAT Chennai10 Nov 2025AY 2010-11

Bench: Shri George George K

For Appellant: Shri Balasubramanian, AdvocateFor Respondent: Shri Vijay Kumar, JCIT

Section 148Section 250Section 271Section 68

were out of her declared business income and receipts of cash gifts from family (parents and relatives) and that she had declared salary and agricultural income in her ITR for the year under consideration. However, she has failed to furnish any documentary evidence in support of her claim with regard

Gottimukkala Vidya Latha, Vijayawada vs. ITO, Ward-1(1), Vijayawada

In the result, appeal of the assessee is allowed

ITA 440/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble

Section 131Section 133(6)Section 143(2)Section 143(3)Section 69A

Ld.Authorised Representative [hereinafter “Ld.AR”] submitted that assessee received an amount of Rs.5 Lakhs from Smt. Divi Kantamma (Mother of the assessee) out of the agricultural income earned by Smt. Divi Kantamma. She submitted that the assessee transferred Rs.6,20,000/- on 27.07.2014 to her mother Smt. Divi Kantamma which ... Ld.DR”] relied on the orders of the Revenue Authorities and submitted that the assessee has not produced any evidences with regarding to earning of agricultural income but has submitted only land holding documents. Therefore, the genuineness of the income cannot be believed and hence addition made

Jain Babulal Champatlal, Vijayawada vs. Income Tax Officer, Ward 2(1), Vijayawada

In the result, both the appeals filed by the assessee are 9

ITA 395/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.Nos.394 & 395/Viz/2025 (निर्धारणवर्ा/ Assessment Year:2017-18) Vs. Jain Babulal Champatlal Income Tax Officer – Ward – 2(1) Cr Building, 1St Floor Annex 40-1-155, Lgf Mg Road, Vijayawada – 520002 Ripples Mall, M.G. Road Andhra Pradesh Vijayawada-520010 Andhra Pradesh [Pan:Aefpc1220F]

Section 142(1)Section 143(2)Section 143(3)Section 270ASection 57

Suraj Constructions, filed his return of income for the A.Y. 2017-18 on 22.10.2017 admitting a total income of Rs.22,43,340/- and agricultural income of Rs.57,900/-. Subsequently, the case was selected for limited scrutiny under CASS. Accordingly, statutory notices under section

Jain Babulal Champatlal, Vijayawada vs. Income Tax Officer, Ward 2(1), Vijayawada

In the result, both the appeals filed by the assessee are 9

ITA 394/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam07 Nov 2025AY 2017-18

Section 142(1)Section 143(2)Section 143(3)Section 270ASection 57

Pentyala Madhavi, Hyderabad vs. Income Tax Officer, Ward-12(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 392/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad07 Nov 2025AY 2015-2016

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

Section 139Section 142(1)Section 144Section 147Section 148Section 69A

Vijaya Bank for Rs. 11,75,000/-. Therefore, the A.O. made additions under Section 69A of the Act. Further, the A.O. treated the agricultural income of Rs. 1,75,000/- claimed by the assessee in her return of income filed on 28-05- 2022 as income from other sources ... towards cash deposits into the bank account and also the addition of Rs. 1,75,000/- under the head “Income from Other Sources” towards agricultural income reported in the 4 Pentyala Madhavi. return of income. The Ld. CIT(A), after considering the submissions of the assessee and also taking note

Jagadishwar Barma, Hyderabad vs. ITO, Ward-11(2), Hyderabad

ITA 1436/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Nov 2025AY 2017-18

Bench: Us:

Section 115BSection 143(3)Section 2(14)Section 294Section 69A

Abraham Varghese Charuvil (ITA No. 30/Coch/2017), wherein surplus from sale of agricultural land was held to partake the character of agricultural income. 9. The authorities below erred in invoking section 115BBE of the Act even after the appellant had explained the source of deposits. The provisions of section 115BBE have

Viva Boards Private Limited, Nizamabad vs. DCIT., Circle-8(1), Hyderabad

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

ITA 1303/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Nov 2025AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 115BSection 131Section 142(1)Section 143(2)Section 68

Shri Harshavardhan Pattipati. The assessee company has also explained the reasons for the cash deposit into the account of the creditor out of his agricultural income. Insofar as the non-furnishing of PAN numbers and ITRs of Pattipati Suchitra and Pattipati Srujan, both are minor children of the Director, Shri ... assessee company has explained the transactions with relevant details and argued that, Shri Pattipati Harshavardhan is an agriculturist, and out of his agricultural income, he has deposited the cash into bank account. The A.O. on the basis of one instance of cash deposit in the bank account of Pattipati Harshavardhan

Arvind Nandagopal, Chennai vs. ACIT, CC-3(1), Chennai

In the result, all appeals filed by the assessee are allowed

ITA 2274/CHNY/2024[2018-19]Status: DisposedITAT Chennai07 Nov 2025AY 2018-19

Section 131Section 132

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