“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

Subal Chandra Nag, Dhanbad vs. ACIT, Circle-2, Dhanbad

In the result, both appeals of the assessee are allowed

ITA 92/RAN/2023[2014-15]Status: DisposedITAT Ranchi10 Oct 2025AY 2014-15

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri Khubchand T. Pandya, Sr.DR

Shri Khubchand T. Pandya, Sr.DR appeared on behalf of the revenue. 3. It was submitted by the ld AR that the assessee had disclosed agricultural income of Rs.6,12,500/- in the assessment year 2015-2016 and Rs.6,10,000/- in the assessment year 2014-2015. It was the submission ... that the AO had disallowed agriculture income disclosed by the assessee holding the same as assessee’s income from other sources. It was the submission that the AO himself has accepted for the assessment year 2014-2015 the gross sales of agriculture produce is at Rs.16

Rakesh Jayantibhai Patel, Ahmedabad vs. Income Tax Officer, Ward - 5(3)(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1301/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri Vimal Desai, ARFor Respondent: Shri Sudhakar Verma, Sr.DR

Section 115BSection 147Section 58Section 68

been advanced to the appellant during this period. Whereas it cannot be denied that Jayantibhai Bhavji Bhai Patel was having agricultural income and must be having past savings also, it can also not be denied that he would be incurring expences on the maintenance and well being of his family

Ajmer Singh, Rohtak vs. ITO, Ward - 1, Rohtak

In the result, appeal of the assessee is partly allowed

ITA 2661/DEL/2025[2017-18]Status: DisposedITAT Delhi10 Oct 2025AY 2017-18

Bench: Shri Vikas Awasthyआअसं.2661/िद"ी/2025 (िन.व. 2017-18) Ajmer Singh, S/O Shri Kapoor Singh, Village Sunaria Khurd, P.O. Sunaria Kalan, ...... अपीलाथ"/Appellant Tehsil & Distt. Rohtak, Haryana 124001 Pan: Bcxps-1094-Q बनाम Vs. Income Tax Officer, ..... "ितवादी/Respondent Ward-1, Rohtak, Haryana 124001 अपीलाथ" "ारा/Appellant By : Shri Naveen Gupta, Advocate "ितवादी"ारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 15/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 10/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit’(A)’] Dated 27.03.2025, For Assessment Year 2017-18. 2. Shri Naveen Gupta, Appearing On Behalf Of The Assessee Submitted That The Assessee Is An Ex-Serviceman & Owns Agricultural Land To The Extent Of 4.5 Acres At Village Sunari Khurd, Tehsil & District Rohtak. The Assessing Officer (Ao) Made Addition To The Tune Of Rs.27,75,000/- In Ex-Parte Proceedings On Account Of Unexplained Cash Deposits In Two Bank Accounts Of The Assessee I.E.

For Appellant: Shri Naveen Gupta, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR

Section 69A

agricultural land. Since the transaction did not materialized the cash amount was kept by the assessee at home in his chest. The assessee had agricultural income from his agricultural land. Thus, remaining amount was deposited from earlier savings and the agricultural income of the assessee. The assessee in support ... sugarcane on the land. The CIT(A) granted part relief to the assessee acknowledging that part of deposits were from earlier withdrawals and agricultural income. Having accepted the fact of earlier withdrawals, the CIT(A) ought to have given full relief on account of earlier withdrawals. 4. Per contra, Shri

Ratanshi, Rajkot vs. Income Tax Officer, Morbi

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

ITA 171/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Oct 2025AY 2017-18

For Appellant: Shri Kalpesh Parekh, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 139Section 143(3)Section 250Section 69A

income u/s 139 of the income-tax Act, 1961, vide acknowledgement number 499879880250318 on 25/03/2018 declaring total income of Rs. Nil/- and also agriculture income of Rs. 2,06,609/-. The case was selected for limited scrutiny under CASS for the examination of reason "cash deposit during demonstration period". During

Sridhar Maramreddy, Hyderabad vs. ITO., Ward-8(1), Hyderabad

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

ITA 504/HYD/2025[2017-18]Status: DisposedITAT Hyderabad09 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Raoआ.अपी.सं /Ita No.504/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2017-18) Shri Sridhar Maramreddy, Income Tax Officer, Vs. Ward 8(1), Hyderabad. Hyderabad. Pan:Bqhpm4916K (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Abhishek Murali, C.A. रधजस् व द्वधरध/Revenue By: Shri Kumar Aditya, Dr सुिवधई की तधरीख/Date Of 07/10/2025 Hearing: घोर्णध की 09/10/2025 तधरीख/Pronouncement: आदेश/Order Per Inturi Rama Rao : This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 27.01.2025

For Appellant: Shri Abhishek Murali, C.AFor Respondent: Shri Kumar Aditya, DR

assessee is an individual, filed his e-return for the A.Y. 2017-18 on 16.12.2017 declaring total income of Rs.7,12,190/- and agricultural income of Rs.4,17,300/-. ITA No.504/Hyd/2025 2 The case was selected for limited scrutiny through CASS, notice was issued by the Assessing Officer

Sheela Holabasappa Mudareddi, Narayanpur, Dharwad vs. Income Tax Officer, Ward 1(1), Navanagar, Hubballi

In the result, the appeal of the assessee is allowed

ITA 1155/BANG/2025[2017-2018]Status: DisposedITAT Bangalore09 Oct 2025AY 2017-2018

Bench: Shri Narender Kumar Chodhry & Shri Waseem Ahmedassessment Year: 2017-18

For Appellant: Shri Hemant Kumar M Shrupali, CAFor Respondent: Shri Ganesh R Ghale, Standing Counsel for Department

Section 69A

during the demonetisation period. The assessee explained that there was a cash withdrawal of ₹5,70,000 earlier, which was redeposited. She also claimed agricultural income. The AO did not accept her explanation and treated the cash deposit as unexplained under section ... There was a cash withdrawal of ₹5,70,000 which was not shown to be used elsewhere. That cash was available for redeposit. Further, agricultural income was also there to support availability of cash. The assessee being an individual is entitled to a basic exemption limit

Kanigere Ramegowda Ningaraju, Hassan vs. Income Tax Officer, Ward 1 & Tps, Hassan

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

ITA 1046/BANG/2025[2015-16]Status: DisposedITAT Bangalore09 Oct 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Years : 2015-16

For Appellant: Shri V Shivarama Iyer, C.AFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)

Section 144BSection 147Section 148Section 148ASection 263Section 269SSection 45

explained the source of cash deposits of ₹59,00,000 in the bank account by stating that a sum of ₹7,50,000 represented agricultural income from coffee and pepper produce, while ₹51,50,000 was received as sale proceeds from Silver Oak trees. In addition, the assessee had deposited

Vijaya Prakash Ghosalkar, Mumbai vs. Commissioner of Income-Tax (Appeals), Mumbai

Appeal of the assessee is partly allowed

ITA 5050/MUM/2025[2017-18]Status: DisposedITAT Mumbai09 Oct 2025AY 2017-18

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

For Appellant: Shri Siddharth Vora, ARFor Respondent: Shri Nagnath Pasale, Sr. DR

Section 115BSection 143(2)Section 148Section 234Section 250

banquet HD Goankar AC Hall, Plot no.89, Borivalli(E), Mumbai. Accordingly, the assessee submits that she had, during the FY 2016-17, agricultural income of Rs. 15,79,655/-, business income of Rs.8.37.700/- and of past savings from business & agricultural income of Rs. 18,82,645/. The assessee also filed ... under section 148 filed the return of income declaring income from business, interest income. Before the CIT(A) the assessee submitted that he had agricultural income to the tune of Rs. 15,79,655 and the ld AR before us submitted a statement containing the details of agricultural income earned

ACIT, CC-2, Chandigarh vs. Shri Karaj Singh, Yamuna Nagar

In the result, the revenue’s appeal ITA No

ITA 726/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh08 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No. 726/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) Acit-Central Circle 2 Shri Karaj Singh बनाम/ Cr Building Sector 17 H. No 1379, Modern Colony, Near Iti Vs. Chandigarh 160017 Yamuna Nagar (Haryana) "ायीलेखासं./जीआइआरसं./Pan/Gir No. Atups-5528-A (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. Co. No. 16/Chandi/2024 [In Ita No. 726/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) Shri Karaj Singh Acit-Central Circle 2 बनाम/ H. No 1379, Modern Colony, Near Iti, Cr Building Sector 17 Vs. Yamuna Nagar (Haryana) Chandigarh 160017 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Atups-5528-A (Cross-Objector) : (Respondent) Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr Assessee By : Shri Dhruv Goel (Ca) - Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 18-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 08/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By Revenue For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)- 3, Gurgaon [Cit(A)] Dated 26-09-2022 In The Matter Of An Assessment

For Appellant: Shri Dhruv Goel (CA) - Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR

Section 143(3)Section 153Section 153ASection 153DSection 68

case and in law the Ld. CIT(A) is right in allowing the appeal of the assessee on the issue of restricting agriculture income by not appreciating the facts that the assessee did not furnish complete documents in support of agriculture income declared in ITR? 1.2 The assessee has filed ... appeals are- (i) Estimation of Net profit Rate; (ii) Deletion of addition of Unsecured loans for Rs.16 Lacs; (iii) Deletion of addition of Agricultural income. The issues in assessee’s cross-objections are – (i) Estimation of Net profit Rate; (ii) Addition of Unsecured loans for Rs.10 Lacs; (iii) Mechanical approval

Dineshbhai Manibhai Patel, Anand vs. The ITO, Ward-2, Anand

In the result, appeal filed by the assessee is allowed

ITA 997/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2012-13

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri Aseem Thakkar, ARFor Respondent: Shri Rajiv Garg, Sr.DR

Section 133(6)Section 143(3)Section 147Section 250Section 69A

through the orders of the authorities below. We have noted that the assessee’s justification of the cash deposit in his bank account was agricultural income earned by him. To justify the same, he submitted copies of revenue records reflecting his land holding of agricultural land. He had also submitted ... Rs.8,62,000/- in the bank account of the assessee stood accepted by the Ld. CIT(A) as sourced from agricultural income earned by the assessee. The balance was not agreed by him noting that the amounts deposited in the bank in cash did not tally with the bills

Sesham Ramanaiah, Prakasam vs. ITO., Ward-1, Ongole

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

ITA 1062/HYD/2025[2016-17]Status: FixedITAT Hyderabad08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Ms. Swathi Sheela, C.AFor Respondent: Dr. Sachin Kumar, SR-DR

Section 139Section 147Section 148Section 69Section 69A

being called upon to explain, the assessee submitted that the deposits came out of income from dealing of paddy, other commission income and agricultural income from lands held in the name of his family, including savings of earlier years. However, since no documentary evidence was filed ... addition under section 69A, the Ld. AR submitted that the assessee had taken agricultural land on lease from various persons and earned agricultural income therefrom. In support of his contention, the Ld. AR invited our attention to the copies of lease agreements, landholding details and income computation for various years

Amarjot Singh Village Babehali Distt Gurdaspur, Gurdaspur vs. Income Tax Officer Ward Gurdaspur G T Road Gurdaspur, Gurdaspur

In the result, all the five appeals filed by the assessee are allowed for statistical

ITA 103/ASR/2025[2017-2018]Status: DisposedITAT Amritsar07 Oct 2025AY 2017-2018

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. P. N. Arora, Adv

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 69

assessee is engaged in agricultural activity and has filed his regular return declaring an income of Rs. 2.31 lakhs from other source and agricultural income of Rs. 22.70 lakhs, which has been assessed u/s 143(3) of the Act 61. 4. Subsequently, on information from investigation wing and verification

Amarjot Singh Village Babehali Distt Gurdaspur, Gurdaspur vs. Income Tax Officer Ward Gurdaspur, Gurdaspur

In the result, all the five appeals filed by the assessee are allowed for statistical

ITA 102/ASR/2025[2017-2018]Status: DisposedITAT Amritsar07 Oct 2025AY 2017-2018

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. P. N. Arora, Adv

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 69

Amarjot Singh Village Babehali Distt Gurdaspur, Gurdaspur vs. Income Tax Officer Ward Gurdaspur, Gurdaspur

In the result, all the five appeals filed by the assessee are allowed for statistical

ITA 101/ASR/2025[2015-2016]Status: DisposedITAT Amritsar07 Oct 2025AY 2015-2016

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. P. N. Arora, Adv

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 69

Amarjot Singh, Village Babehali Distt Gurdaspur vs. Income Tax Officer Gurdaspur, Gurdaspur

In the result, all the five appeals filed by the assessee are allowed for statistical

ITA 598/ASR/2024[2017-2018]Status: DisposedITAT Amritsar07 Oct 2025AY 2017-2018

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. P. N. Arora, Adv

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 69

Amarjot Singh, Gurdaspur vs. Income Tax Officer Ward Gurdaspur, Gurdaspur

In the result, all the five appeals filed by the assessee are allowed for statistical

ITA 597/ASR/2024[2015-2016]Status: DisposedITAT Amritsar07 Oct 2025AY 2015-2016

Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta

For Appellant: Sh. P. N. Arora, Adv

Section 142(1)Section 143(3)Section 147Section 148Section 250Section 69

Zaimur Rahman, East Champaran vs. Income Tax Department, NFAC, Delhi

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

ITA 321/PAT/2025[2015-16]Status: DisposedITAT Patna07 Oct 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 144BSection 147Section 148Section 149Section 250Section 68Section 69A

unexplained cash deposits in bank, ₹3,45,16,118/- u/s 68 of the Act for unexplained capital, ₹21,08,600/- for unsubstantiated agricultural income treated as income from other sources, ₹33,20,000/- for Short Term Capital Gain on sale of immovable property and the total income was computed

Alpeshbhai Baldevbhai Rabari, Mehsana vs. The ITO, Ward-1, Mehsana

In the result, the appeal of the assessee is treated as allowed for statistical purpose

ITA 1237/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad07 Oct 2025AY 2017-18

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2017-2018 Alpeshbhai Baldevbhai Rabari Ito, Ward-1 3, Rabarivas, Palaj Vs. Mehsana. Mehsana 384 410 Gujarat. Pan : Bwgpr 0788 H (Applicant) (Responent) : Shri Dhrunal Bhatt, Ar Assessee By : Shri Kalpesh Rupavatia, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 30/09/2025 घोषणा क" तारीख /Date Of Pronouncement: 07/10/2025

For Appellant: Shri Kalpesh Rupavatia, Sr.DR

Section 143(2)Section 144Section 226(3)Section 249(2)Section 249(3)Section 250Section 69A

Correspondent with the Central Bank 2 of India. The assessee filed his return of income declaring a total income of Rs.1,50,000/- and agricultural income of Rs.5,000/-. The return was processed, and the case was selected for scrutiny. However, during the course of assessment proceedings, the assessee

Padam Kumar, Ambur vs. DCIT, Central Circle-3(3), Chennai

In the result, appeals filed by the assessee are dismissed

ITA 637/CHNY/2025[2019-20]Status: DisposedITAT Chennai07 Oct 2025AY 2019-20

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Hitesh, AdvocateFor Respondent: Ms.E.Pavuna Sundari, CIT

Section 143(2)Section 153ASection 68

Since both the parties agreed that the sole issue involved in both the appeals are related to agricultural income of the assessee and therefore, the appeal for AY 2018-19 would be adjudicated and the result of which will be followed for AY 2019-20. ITA Nos.636 & 637/Chny/2025 ... declaring total income of ₹18,32,240/-. For the relevant AY, the assessee has shown to have received income from salary, rent, agricultural income and interest on loans. Search was carried out at the assessee’s premise on 01.11.2018, pursuant to which, notice u/s.153A of the Income

Padam Kumar, Ambur vs. DCIT, Central Circle-3(3), Chennai

In the result, appeals filed by the assessee are dismissed

ITA 636/CHNY/2025[2018-19]Status: DisposedITAT Chennai07 Oct 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

For Appellant: Mr.Hitesh, AdvocateFor Respondent: Ms.E.Pavuna Sundari, CIT

Section 143(2)Section 153ASection 68