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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

Razak Rowther Mohamed Saleem, Dindigul vs. ITO, Ward-1, Dindigul

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

ITA 1731/CHNY/2025[2016-17]Status: DisposedITAT Chennai17 Oct 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1731/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Razak Rowther Mohamed Saleem, Vs. The Income Tax Officer, No. 29A, Manthinapalli Vasal Street, Ward 1, Batlagundu Road, Begampur, Dindigul. Dindigul 624 002. [Pan:Acfpm9762L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. S. Vidya, C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 10.09.2025 घोषणा की तारीख /Date Of Pronouncement : 17.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 15.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. The Assessee Raised 3 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is 2

For Appellant: Ms. S. Vidya, C.AFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 143(1)Section 143(2)Section 2

only issue emanates for our consideration as to whether the ld. CIT(A) is 2 I.T.A. No.1731/Chny/25 justified in confirming the disallowance of agricultural income in the facts and circumstances of the case. 3. We note that the assessee filed his return of income ... admitting total income of ₹.7,65,160/- and agricultural income of ₹.85,84,619/-. The return of income was processed under section 143(1) of the Income Tax Act, 1961[“Act” in short]. The case was subsequently selected for "Limited scrutiny" under CASS and notice under section

Thakorbhai Vasantbhai Patel, Bharuch, Gujarat vs. Income Tax Officer Ward 1(3)- Bharuch, Bharuch, Gujarat

In the result, appeal is partly allowed

ITA 1070/SRT/2024[2017-18]Status: DisposedITAT Surat16 Oct 2025AY 2017-18

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1070/Srt/2024 Assessment Year: 2017-18 (Hybrid Hearing) Thakorbhai Vasantbhai Patel Income Tax Officer Ward-1(3) बनाम/ A-28, Punit Society, Near Bharuch, 1St Floor, Station Road, Vs. Civil Road, Bharuch-392 001 Near Panchwati Chowk, Bharuch- 356 069 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Akcpp 0669 E (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Sapnesh R Sheth, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 28/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 16/10/2025

Section 115BSection 143(3)Section 250Section 69A

NFAC has erred in upholding the addition of Rs.15,45,424/- u/s.69A of the Act despite the fact that appellant has proved sources of agricultural income by producing agriculture income related evidences, i.e., 7/12 and 8A as also sale bills of agriculture produce. ITA No.1070/Srt/2024 A.Y 17-18 Thakorbhai ... same, it was submitted by the assessee that he is an agriculturist and source of the aforesaid cash deposited was from his agricultural income. In order to substantiate his claim, the assessee had furnished the copy of 7/12 and 8A, being proof of having agricultural land. Besides, the assessee

Mohan Lal Yadav, Jaipur vs. ITO Ward -1(1), Jaipur

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

ITA 1223/JPR/2025[2018-19]Status: DisposedITAT Jaipur15 Oct 2025AY 2018-19

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR, JM आयकर अपील सं. / ITA No. 1223/JPR/2025 निर्धारण वर्ष / Assessment Year : 2018-19 Shri Mohan Lal Yadav Vs. The ITO C/o Shri R.S. Poonia, CA Ward 1(1) D-82-B, Siwad Area, Krishna Marg Jaipur Bapu Nagar, Jaipur - 302015 स्थायी लेखा सं. / जीआईआर सं. / PAN/GIR No.: ARMPY 7388Q अपीलार्थी / Appellant प्रत्यर्थी / Respondent निर्धारिती की ओर से / Assessee by : Ms. Payal Jhorar, Advocate राजस्व की ओर से / Revenue by : Shri Ga

For Appellant: Ms. Payal Jhorar, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 69A

case the Ld. CIT (Appeals), NFAC has erred in law and facts in confirming the addition Rs. 1,41,200/- u/s 69A on agricultural income. Kindly delete the same. 2.1 At the outset of hearing of the appeal, it is noticed that the appeal filed by the assessee was filed ... Income Tax Act for the assessment year 2014-15. The case revolves around short term capital gains and denial of claim of agricultural income. The Assessing Officer issued multiple statutory notices under Sections 148, 142(1), and 144 of the Act, to which the appellant failed to respond

Lovely Rani Constructions Private Limited, Patna Bihar vs. Assistant Commissioner of Income Tax, Circle 1, Patna

In the result, ITA Nos.233-235/PAT/2024, ITA Nos

ITA 267/PAT/2024[2012-13]Status: DisposedITAT Patna14 Oct 2025AY 2012-13

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita Nos.233, 234 & 235/Pat/2024 & Saroj Bala, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aaspb 3828 P & आयकर अपील सं/Ita No.267/Pat/24 & Ita Nos.279, 282 & 283/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2016-17 & 2018-19) & Cross Objection No.02/Pat/2023 (Arising Out Of Ita No.295/Pat/2023) (Assessment Year : 2012-2013) Lovely Rani Constructions Pvt Ltd Vs Acit, Circle-1, Patna 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita No.295/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13) Dcit, Central Circle-1, Patna Vs Lovely Rani Constructions Pvt Ltd 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita Nos.272, 273, 274, 275, 276 & 278/Pat/2023 (A.Yrs : 2014-15, 2015-16, 2016-17, 2017-18, 2019-20 & 2018-19) Murlidhar Prasad, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aekpp 1361 D

For Appellant: Shri Prince Chugh, ARFor Respondent: Shri Rajat Datta, CIT-DR
Section 132(1)Section 139(1)Section 142(1)Section 153ASection 153DSection 69A

common. The assessee filed a voluntary return of income on 29.08.2019 declaring total income at Rs.2,96,330/-. Besides the assessee has declared the agricultural income also of Rs.7,15,600/-. The AO treated the said agricultural income to be not acceptable and treated the same as unexplained u/s.69A ... activities were being carried out on the aforesaid land. 27. It was submitted by the ld. AR that the assessee was consistently showing the agricultural income from the assessment year 2011-2012 onwards in the return of income. It was submitted that AY 2012-13 was reopened

Saroj Bala, Patna vs. Assistant Commissioner of Income Tax, Patna

In the result, ITA Nos.233-235/PAT/2024, ITA Nos

ITA 234/PAT/2024[2015-16]Status: DisposedITAT Patna14 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita Nos.233, 234 & 235/Pat/2024 & Saroj Bala, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aaspb 3828 P & आयकर अपील सं/Ita No.267/Pat/24 & Ita Nos.279, 282 & 283/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13, 2013-14, 2016-17 & 2018-19) & Cross Objection No.02/Pat/2023 (Arising Out Of Ita No.295/Pat/2023) (Assessment Year : 2012-2013) Lovely Rani Constructions Pvt Ltd Vs Acit, Circle-1, Patna 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita No.295/Pat/2023 (नििाारण वर्ा / A.Yrs : 2012-13) Dcit, Central Circle-1, Patna Vs Lovely Rani Constructions Pvt Ltd 301, Raj Krishna Apartment, East Boring Canal Road, Patna-800001 Pan No. :Aabcl 8329 H & आयकर अपील सं/Ita Nos.272, 273, 274, 275, 276 & 278/Pat/2023 (A.Yrs : 2014-15, 2015-16, 2016-17, 2017-18, 2019-20 & 2018-19) Murlidhar Prasad, Vs Acit, Central Circle-1, Patna 101, Ramayan Apartment, New Dakbaglow Road, Gandhi Maidan, Patna-800001 Pan No. :Aekpp 1361 D

For Appellant: Shri Prince Chugh, ARFor Respondent: Shri Rajat Datta, CIT-DR
Section 132(1)Section 139(1)Section 142(1)Section 153ASection 153DSection 69A

common. The assessee filed a voluntary return of income on 29.08.2019 declaring total income at Rs.2,96,330/-. Besides the assessee has declared the agricultural income also of Rs.7,15,600/-. The AO treated the said agricultural income to be not acceptable and treated the same as unexplained u/s.69A ... activities were being carried out on the aforesaid land. 27. It was submitted by the ld. AR that the assessee was consistently showing the agricultural income from the assessment year 2011-2012 onwards in the return of income. It was submitted that AY 2012-13 was reopened