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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

Gajendramurthy Rangappa, Hosur vs. ITO, Ward-1, Hosur

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

ITA 1583/CHNY/2025[2020-21]Status: DisposedITAT Chennai09 Sept 2025AY 2020-21

Bench: S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.1583/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Gajendramurthy Rangappa, Vs. The Income Tax Officer, D. No. 3/207/A-1, Avalapalli, Ward 1, Hosur 635 109. Hosur. [Pan:Bljpg7735F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/ Date Of Hearing : 04.09.2025 घोषणा की तारीख /Date Of Pronouncement : 09.09.2025 आदेश /O R D E R This Appeal Filed By The Assessee Is Directed Against The Order Dated 06.03.2025 Passed By The Ld. Principal Commissioner Of Income Tax – 1, Coimbatore For The Assessment Year 2020-21 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: NoneFor Respondent: Ms. E. Pavuna Sundari, CIT
Section 115BSection 143(3)Section 144Section 263Section 69A

Assessing Officer, in the original assessment proceedings, disallowed an amount of ₹.25,68,520/- on account of denial of allowance under the head agricultural income vide scrutiny assessment. The ld. PCIT, while exercising the provisions of section 263 of the Act, held the said assessment order passed under section ... under the provisions of section 115BBE of the Act. I find that the Assessing Officer conducted enquiry and found no evidence in claiming the agricultural income and accordingly, disallowed the same and brought the same under the normal tax rate at 30%, but, not under section 115BBE

Channan Singh, Sangrur vs. Jao Income Tax Officer, Ward Sunam, Punjab

The appeal stand allowed

ITA 740/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh04 Sept 2025AY 2012-13

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं. / Ita No.740/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2012-13) Shri Channan Singh Ito Ward Sunam बनाम/ 125, Ward No 7, Koko Majri, Sunam Mata Modi Road, Preet Nagar Vs. Sangrur-148028 Sunam, Sangrur. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Cxups-2467-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sudhir Sehgal (Advocate) -Ld. Ar ""थ"कीओरसे/Respondent By : Shri Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 02-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-09-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2012-13 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 24-03-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S. 144 R.W.S. 147 Of The Act On 30-12-2018. Having Heard Rival Submissions & Upon Perusal Of Case Records, The Appeal Is Disposed-Off As Under.

For Appellant: Shri Sudhir Sehgal (Advocate) -Ld. ARFor Respondent: Shri Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 144

added the same to the income of the assessee as unexplained money for want of any evidences as forthcoming from the assessee. The declared agricultural income of Rs.3.50 Lacs was assessed as ‘Nil’ for the same very reason. 3. During first appeal, the assessee’s additional evidences were subjected

Thucanaickenpalayam Marannan Manoharan, Erode vs. ITO, Ward-2(4), Erode

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

ITA 824/CHNY/2025[2016-17]Status: DisposedITAT Chennai03 Sept 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 824/Chny/2025 धनिाारण वर्ा / Assessment Year: 2016-17 Thuckanaickenpalayam Marannan Income Tax Officer, Manoharan, Vs. Ward 2(1), Erode. 144, T.N. Palayam Gobi, Erode – 638 506, Tamil Nadu. [Pan: Aaipm-5470-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. P.M Kathir, Advocate & Shri. G. Akash , Advocate प्रत्यथी की ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 28.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 03.09.2025

For Appellant: Shri. P.M Kathir, Advocate and Shri. G. Akash , AdvocateFor Respondent: Ms. Anitha, Addl.CIT
Section 69

tune of Rs.56,69,974/-. During the assessment proceedings, the assessee submitted that the source for the increase in the capital was the agricultural income of Rs.19,50,148/- and proceeds from sale of turmeric stock of Rs.13,86,890/-. On verification of the ITR filed by the assessee ... this year, the AO found that the net agricultural income shown for this year was Rs.14,52,973/- only and that the value of turmeric stock was not disclosed in the ITR. In response, the assessee submitted that the sale of turmeric stock was omitted to be disclosed

Sivakumar, Puducherry vs. ITO, Ward-3. Puducherry, Puducherry

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

ITA 1829/CHNY/2025[2011-12]Status: DisposedITAT Chennai03 Sept 2025AY 2011-12

Bench: Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.1829/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 Sivakumar, Vs. The Income Tax Officer, 54, Main Road, Ariyur, Ward 3, Puducherry 605 102. Puducherry. [Pan:Cxips8770A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Girish Kumar, Advocate For Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Ms. V. Aswathy, Jcit सुनवाई की तारीख/ Date Of Hearing : 01.09.2025 घोषणा की तारीख /Date Of Pronouncement : 03.09.2025 आदेश /O R D E R

For Appellant: Shri Girish Kumar, Advocate for Shri T. Vasudevan, AdvocateFor Respondent: Ms. V. Aswathy, JCIT
Section 144

assessee is that the assessee’s father was an illiterate, agriculturist and his primary source of income was from agriculture. Out of accumulated agricultural income, sale proceeds of agricultural land and by withdrawing ₹.2,00,000/- from his bank account, the assessee’s father gifted ₹.10,00,000/- in cash ... however, the Assessing Officer and the ld. CIT(A) disbelieved the deposit of cash is emanating from sale consideration as well as accumulation of agricultural income. Further, the assessee’s father also confirmed the said deposit is out of sale consideration derived from the sale of his agricultural land