“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

Pedaveeti Swathi, Hyderabad vs. ITO, Ward 9(1), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 1785/HYD/2025[2016-17]Status: DisposedITAT Hyderabad04 Mar 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1785/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Pedaveeti Swathi, Vs. Income Tax Officer, Hyderabad. Ward-9(1), Pan: Fugps2126J Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri T. Chaitanya Kumar, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr.Ar सुनवाई की तारीख/Date Of Hearing: 26/02/2026 घोषणा की तारीख/Date Of 04/03/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 03/06/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 27/02/2024 For The Assessment Year (Ay) 2016-17. The Assessee Has Assailed The Impugned Order Of The Cit(A) On The Following Grounds Of Appeal:

For Appellant: Shri T. Chaitanya KumarFor Respondent: Dr. Sachin Kumar, Sr.AR

Section 115BSection 142(1)Section 144BSection 147Section 148Section 148ASection 149Section 151ASection 69A

unsustainable. 3 Pedaveeti Swathi vs. ITO 8. The learned authorities erred in disregarding the appellant's explanation that the cash deposits were sourced from agricultural income earned from family agricultural lands measuring 36.25 acres. The addition made u/s 69A without verifying ownership and revenue records is unjustified ... failed to conduct any independent verification or enquiry regarding the genuineness of agricultural income, family ownership, or NRE bank transactions. The order was passed mechanically, only relying on AIR information and without any supporting material to conclude escapement of income. 10. The addition

Parvathaneni Praveen, Khammam vs. Income Tax Officer, Ward-1, Khammam

In the result, appeal of the Assessee is dismissed

ITA 1271/HYD/2025[2021-22]Status: DisposedITAT Hyderabad04 Mar 2026AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiao.4Tt.A /Ita.No.1271/Hyd/2025

For Appellant: Sri KA Sai Prasad, CAFor Respondent: Dr. Sachin Kumar, Sr. AR

ITA.No.1271/Hyd./2025 account of Rs.25,29,300/- as unexplained money u/s 694A, without appreciating the fact that these were made out of the agricultural income of the appellant's wife. 5. The Learned CIT(A) is not justified in confirming the addition made by the Assessing officer towards Other ... such information was recorded in the return of income. Purchase Deed enclosed (Enclosure- 5). The purchase consideration is met by me out of the agriculture income of my wife Smt. R. Bhavani Devi who has 16 Acres (aprox.) of agriculture land. Copy of the Form-18 showing the ownership

Gopal Reddy Gattu, Hyderabad vs. ACIT., Circle-5(1), Hyderabad

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

ITA 1011/HYD/2025[2021-22]Status: DisposedITAT Hyderabad04 Mar 2026AY 2021-22

Section 143(3)Section 263

also made addition of Rs. 4,95,000/- under the head “Income from other sources” towards agricultural income claimed by the assessee. 8. The case has been subsequently taken up for revision proceedings and a show-cause notice under Section 263 of the Act, dated 14.10.2024 was issued and called ... estimating net profit of 5% on total turnover and making addition of Rs. 4,95,000/- under the head ‘income from other sources’ towards agricultural income claimed by the assessee. However, while completing the assessment, the A.O. failed to consider the direct and indirect income reported by the assessee

Tiruchangodu Ramasamy Khannaiyann Sarasuwathi, Coimbatore vs. DCIT, Central Circle-1, Coimbatore

ITA 3135/CHNY/2025[2014-15]Status: DisposedITAT Chennai04 Mar 2026AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. T. Banusekar, AdvocateFor Respondent: Ms. T. Mythili, JCIT

Section 142A(6)Section 143(3)Section 234ASection 250Section 50CSection 56(2)(vii)

from this, the AO has also made an addition in respect of long term capital gains arising from sale of property and disallowance of agricultural income, details of which are discussed in ensuing paragraphs. 6. The AO completed the assessment by passing an order u/s.143(3) dated 31.12.2016 assessing ... land and market value adopted by stamp duty authorities in respect of sale of property in two undivided half shares. c) Disallowance of agricultural income of Rs.15,87,241/-. 7. Aggrieved by the order of the AO, the assessee filed an appeal before the Commissioner of Income Tax (Appeals

Jayakumar Thomas Jayaraj, Tirunelveli vs. DCIT Circle 1, Tirunelveli

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

ITA 2885/CHNY/2025[2015-16]Status: DisposedITAT Chennai04 Mar 2026AY 2015-16

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2885/Chny/2025 निर्धारण वर्ष/Assessment Year: 2015-16 Jayakumar Thomas, 3/69K, Madurai-Kanyakumari Bye Pass Road, Reddiyar Patti, Tirunelveli-627 002. [Pan: Acppj 8535 L] (अपीलार्थी/Appellant) V. The Dcit, Circle-1, Tirunelveli. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Ms. Joshita Jothi प्रत्यर्थी की ओर से /Respondent By : Ms.R. Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 29.01.2026 घोषणाकीतारीख /Date Of Pronouncement : 04.03.2026 आदेश / Order Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)/Nfac, (Hereinafter Referred To As “The Ld.Cit(A)”), Delhi, Dated 25.08.2025 For The

For Appellant: Ms. Joshita JothiFor Respondent: Ms.R. Anitha, Addl.CIT

Section 131Section 68

perusal of the same reveals that the assessee has shown in Schedule-EI details of exempt income [Item No.4 which includes agricultural income an amount of ₹3,59,65,360/- which includes capital gains to the tune of ₹3,49,42,060/- which fact has been brought to the notice ... from her savings account. She is an agriculturist and she had agricultural income. Once she demonstrated that she was in possession of ₹.7,00,000/- cash plus agricultural income on her hands, if after 40 days, a cash deposit is made to the extent of about ₹.5,20,000/- towards

Bipinkumar Manilal Thakor, Gandhinagar, Gujarat vs. Income Tax Officer, Ward-1, Gandhinagar, Udyog Bhavan

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

ITA 1908/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad03 Mar 2026AY 2013-14

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2013-14

For Appellant: Hardav Shah, A.RFor Respondent: Shri Veerbadram Vislavath, Sr. D.R

Section 10(1)Section 133(6)Section 139(1)Section 143(3)Section 148Section 276CSection 69A

that in view of the judicial decisions in CIT v. Smt. Santosh Sharma (supra) and Raghubir Singh v. ITO (supra), cash deposits derived from agricultural income should not be treated as unexplained money under Section 69A.” 3. The assessee did not file return of income u/s. 139(1)/139

Bharatsinh Jaysinh Varachhia, Bharuch vs. ITO, Ward 1(1), Bharuch

In the result, both the appeals are allowed

ITA 376/SRT/2025[2017-18]Status: DisposedITAT Surat27 Feb 2026AY 2017-18

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kambleita Nos. 376 & 1175/Srt/2025 Assessment Year 2017-18

For Appellant: Shri Hemant Suthar, C.AFor Respondent: Shri Ashish Kumar, Sr. D.R

Section 133(6)Section 139Section 142(1)Section 271ASection 69A

cash deposits and cash withdrawals to the extent of Rs. 5,80,000/- + Rs. 2,90,000/-. But this amount was that of agricultural income along with the loan account deposits 3 I.T.A Nos. 376 & 1175/Srt/2025 Bharatsinh Jaysinh Varachhia, A.Y.2017-18 through agricultural income. The assessee has given the details ... sales invoices and agricultural produce invoices along with land documents and agricultural income proof which was totally ignored by the Assessing Officer. The CIT(A) has not taken cognizance of the same and confirmed the addition partially which is not justifiable. 7. The ld. D.R. relied the assessment order

Bharatsinh Jaysinh Varachhiya, Bharuch vs. ITO, Ward 1(1), Bharuch

In the result, both the appeals are allowed

ITA 1175/SRT/2025[2017-18]Status: DisposedITAT Surat27 Feb 2026AY 2017-18

Bench: Dr. Brr Kumar, Hon’Ble & Ms. Suchitra Kambleita Nos. 376 & 1175/Srt/2025 Assessment Year 2017-18

For Appellant: Shri Hemant Suthar, C.AFor Respondent: Shri Ashish Kumar, Sr. D.R

Section 133(6)Section 139Section 142(1)Section 271ASection 69A

Arehalli Rudrappa Vishwanatha, Arehally, Temple, Belur vs. Income- Tax Officer, Ward-1 & Tps, Hassan

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

ITA 2654/BANG/2025[2016-17]Status: DisposedITAT Bangalore27 Feb 2026AY 2016-17

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Shri Srikrishna Kantila, CAFor Respondent: Shri Balusamy N, JCIT-DR

Section 10(1)Section 142(1)Section 148Section 148ASection 250Section 44ASection 80C

limit for the relevant assessment year. 6. The learned CIT Appeals has further erred in not appreciating that part of the cash deposits represented agricultural income from the appellant's 4 acres of agricultural land, which is exempt under section 10(1) of the Act. 7. The learned Commissioner

M/S Bhagirath Dairy Private Limited, Nagaur vs. Assistant Commissioner of Income Tax, Nagaur

The appeal is allowed

ITA 755/JODH/2025[2017-18]Status: DisposedITAT Jodhpur26 Feb 2026AY 2017-18

Bench: Dr. Mitha Lal Meena, Hon’Ble & Shri Sudhir Pareek, Hon’Ble

Section 131Section 143(3)Section 44Section 68Section 69Section 69A

agricultural land was purchased afterwards on 24/2/2020 and the same does not fall in the assessment year 2017-18. As such, the question of agricultural income during the year under consideration did not arise. Both the Learned Assessing Officer as well as Learned CIT(A) apparently were misled. They have ... five trucks No.RJ-37 GA- 1701, RJ-37-GA-4438, RJ-37-GA-4818, RJ-37 GA-5491 and RJ-37-GA-5492 besides agricultural income. It seems that Assessing Officer had an imaginary impression about the depositor that he had agricultural land, but no evidence was furnished regarding agricultural

Gurjant Singh, Part Valtoha Patti vs. ITO Ward 1 Tarn Taran, ITO Ward Tarn Taran

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

ITA 615/ASR/2024[2017-18]Status: DisposedITAT Amritsar26 Feb 2026AY 2017-18

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

For Appellant: Sh. Ashwani Kalia, C. A

Section 142(1)Section 144Section 250Section 69A

sale proceeds of agricultural crops and he prays for an opportunity of furnishing of documentary evidences to support his contention of and agricultural income. 6. The ld. DR relied on the order of the ld. CIT(A) and has submitted that the assessee in spite of so many opportunities ... assessee has not filed any documentary evidences to establish the existence of agricultural land holdings and sale of agricultural produce which might result in agricultural income as claimed. As such, we consider it to be a fit case where cost should be imposed and as such, a cost

Gurjant Singh, Valtoha Patti Tarn Taran vs. ITO Ward 1 Tarn Taran, ITO Ward Tarn Taran

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

ITA 614/ASR/2024[2017-2018]Status: DisposedITAT Amritsar26 Feb 2026AY 2017-2018

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

For Appellant: Sh. Ashwani Kalia, C. A

Section 142(1)Section 144Section 250Section 69A

Venkata Ramana Murthy Bollapragada, Hyderabad vs. ITO, Ward-13(1), Hyderabad

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1961/HYD/2025[2016-17]Status: DisposedITAT Hyderabad26 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1961/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Venkata Ramana Murthy Vs. Income Tax Officer, Bollapragada, Ward-13(1), Hyderabad. Hyderabad. Pan: Abmpb7770R (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 24/02/2026 घोषणा की तारीख/Date Of 26/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 27/10/2025, Which In Turn Arises From The Order Passed By The Additional/Joint Commissioner Of Income Tax, Range-13, Hyderabad Under Section 271D Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/06/2022 For The Assessment Year

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Sachin Kumar, Sr. AR

Section 143(3)Section 269SSection 271DSection 274Section 54F

cooperative bank etc. As per the second proviso, this provision would also not be applicable where both the depositor and the receiver are having agricultural income and neither of them has any income chargeable to tax under the Act. 18. Section 271D of the Act deals with penalty for failure

Western Conglomerate Ltd., Kolkata vs. I.T.O., Ward - 4(4), Kolkata

In the result, the appeals of the assessee are allowed for statistical

ITA 2646/KOL/2025[2019-2020]Status: DisposedITAT Kolkata26 Feb 2026AY 2019-2020

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Anil Kochar, ARFor Respondent: Shri S.B. Chakraborthy, DR

Section 143(1)Section 36(1)(va)

assessed by following the Rules 8 of income tax rules pursuant to which the 60% of the income should be treated as agricultural income and 40% should be taxed . The Id. counsel therefore submitted that therefore, the disallowance has to be restricted to 40% which is attributable to the taxable ... assessed as per Rule 8 of the IT Rules, which provides that 60% of the income has to be treated as agricultural income which is exempt and only taxable income would be only to the extent of 40% of the total income under the Act. Thus, we find merit

Western Conglomerate Ltd., Kolkata vs. I.T.O., Ward - 4(4), Kolkata

In the result, the appeals of the assessee are allowed for statistical

ITA 2645/KOL/2025[2018-2019]Status: DisposedITAT Kolkata26 Feb 2026AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Anil Kochar, ARFor Respondent: Shri S.B. Chakraborthy, DR

Section 143(1)Section 36(1)(va)

Maruti Trust, Kolkata vs. I.T.O., Ward - 30(1), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2312/KOL/2025[2024-2025]Status: DisposedITAT Kolkata26 Feb 2026AY 2024-2025

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Ms. Mita Rizvi, ARFor Respondent: Shri Santanu Ghosh, DR

Section 139(1)Section 143(1)Section 164Section 167BSection 2

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

Maruti Trust, Kolkata vs. I.T.O., Ward - 30(1), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2311/KOL/2025[2023-2024]Status: DisposedITAT Kolkata26 Feb 2026AY 2023-2024

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm**

Section 139(1)Section 143(1)Section 164Section 167BSection 2

Maruti Trust, Kolkata vs. I.T.O., Ward - 30(1), Kolkata

In the result, the appeals of the assessee are allowed

ITA 2310/KOL/2025[2022-2023]Status: DisposedITAT Kolkata26 Feb 2026AY 2022-2023

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Ms. Mita Rizvi, ARFor Respondent: Shri Santanu Ghosh, DR

Section 139(1)Section 143(1)Section 164Section 167BSection 2

Deputy Commissioner of Income Tax, Cnetral Circle-4(3), Kolkata vs. Dilip Kumar Ghosh, Kolkata

In the result, the appeal of the Revenue and CO of the Assessee are

ITA 1606/KOL/2025[2018-19]Status: DisposedITAT Kolkata26 Feb 2026AY 2018-19

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: Shri Siddharth Jhajharia, ARFor Respondent: Shri Madhu Malti Ghosh, DR

Section 115BSection 153ASection 69A

director of Jagatbandhu Tea Estate Pvt. Ltd. which is engaged in the activity of growing and selling tea leaves, income from which falls under Agricultural Income. During the search operation u/s 132 of the Act, incriminating documents marked ‘DKG-01’ to ‘DKG-09’were seized from the premises ... Estate Pvt. Ltd. 7.3.2 M/s. Jagatbandhu Tea Estate Pvt. Ltd. is growing and selling tea leaves, income from which falls under the category of Agricultural Income which is exempt u/s 10(1) of the Income Tax Act, 1961. The AO failed to prove that the cash receipts noted

Hemant Kumar Tikariha, Raipur vs. Income Tax Officer, Ward-1(1), Raipur

In the result, appeal of the assessee in ITA No

ITA 98/RPR/2026[2012-13]Status: DisposedITAT Raipur25 Feb 2026AY 2012-13

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.97 & 98/Rpr/2026 "नधा"रण वष" /Assessment Years : 2011-12 & 2012-13

For Appellant: Shri Prafulla Pendse, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 69Section 69A

carefully examined. The appellant has furnished a cash book in support of the sources of cash deposits, claiming receipts from contract work, gold loan, agricultural income, and a gift received from her mother. The cash book and supporting documents submitted in this regard have been perused in detail ... remains unsubstantiated and is accordingly treated as the appellant's own unexplained money. 5.5 The appellant has further claimed that the cash deposits represent agricultural income and has relied upon a certificate issued by Jila Sahakari Bank stating that the deposits were out of sale proceeds of agricultural produce. However