“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

Shree Sharanavasaceshwar Credit Souhard Sahakari Ni Halingali, Halingali vs. Income Tax Officer, Ward-1, Bagalkot

In the result, appeal filed by the assessee is allowed

ITA 154/BANG/2025[2016-17]Status: DisposedITAT Bangalore12 Aug 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2016-17 Shree Sharanabasaveshwar Credit Souhard Sahakari Ni Halingali Ito Tq Jamkhandi, Dt Bagalkot Vs. Ward-1 Halingali, Karnataka 587315 Bagalkot Pan No :Aaeas6699C Appellant Respondent Appellant By : Sri Sandeep Chalapathy, A.R. Respondent By : Sri Subramanian S., D.R. Date Of Hearing : 14.05.2025 Date Of Pronouncement : 12.08.2025 O R D E R Per Keshav Dubey: This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The Ld. Cit(A)/Nfac Dated 07.11.2024 Vide Din & Order No. Itba/Nfac/S/250/2024-25/1070176573(1) Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”) For The Assessment Year 2016-17. 2. The Assessee Has Raised The Following Ground Of Appeal: -

For Appellant: Sri Sandeep Chalapathy, A.RFor Respondent: Sri Subramanian S., D.R

Section 143(3)Section 250Section 271(1)(c)Section 274Section 80PSection 80P(2)Section 80P(2)(a)

losses, suppression of sales, camouflage of income as loans taken from third parties and claim of interest thereon as deduction, giving a colour of agricultural income to the otherwise taxable income, and unexplained investments that can be clearly attributed to concealed income. However, mere addition or estimates made on mere

Arees Erinhikkath, Tirur vs. ITO, Ward 1 & Tps, Tirur

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

ITA 483/COCH/2025[2016-17]Status: DisposedITAT Cochin11 Aug 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2016-17 Arees Erinhikkath, .......... Appellant Erinhikkath House, Poilissery, Alathiyur, Kerala. [Pan: Achpe 5987 F] Vs. Income Tax Officer .......... Respondent Ward-1 & Tps, Tirur. Appellant By: Shri Shaji Poulose, Ca Respondent By: Smt. Leena Lal, Sr. Dr Date Of Hearing: 06.08.2025 Date Of Pronouncement: 11.08.2025

For Appellant: Shri Shaji Poulose, CAFor Respondent: Smt. Leena Lal, Sr. DR

Section 143(3)

assessee is an individual. The return of income for the A.Y. 2016-17 was filed on 16/03/2018 disclosing income of Rs. 95,670/- and agricultural income of Rs. 2 Arees Erinhikkath 58,200/-. Against the said return of income, the assessment was completed by the ITO, Ward-1 & TPS, Tirur

Dharmendra Kumar, Bhanwargarh vs. Income Tax Officer, Baran

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

ITA 1322/JPR/2024[2016-17]Status: DisposedITAT Jaipur11 Aug 2025AY 2016-17

Bench: BEFORE: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Swapnil Agarwal, CA, (Thru: V.C.)For Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 249(4)

during the year under consideration assessee deposited Rs.16,03,000/- in Baran KendriyaSahkari Bank Ltd. Source of above cash deposit was that assessee having agriculture income only which is exempt under Income Tax Act. Assessee hold 60 Bighas agriculture land since last 25 years. If we consider agriculture income ... then Rs.6,00,000/- on dated 24-12-2015 from CBI. So now we would like to say that having agriculture income only which arise only in cash. Please consider the request.’’ 2.1 During the course of hearing, the Bench noted that there is delay of 189 days in filing

Sh. Sukhbir Singh Badal, Muktsar vs. The Dy. Commissioner of Income Tax, Bathinda

Appeal stand allowed

ITA 411/ASR/2010[2000-01]Status: DisposedITAT Amritsar07 Aug 2025AY 2000-01

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Udayan Das Gupta, Jm आयकर अपील सं./ Ita No. 411/Asr/2010 (िनधा"रण वष" / Assessment Year: 2000-01) Shri Sukhbir Singh Badal Dcit-Circle-Ii बनाम/ Vs. S/O Parkash Singh Badal Bhatinda. Vpo Badal, District Muktsar "थायीलेखासं./जीआइआरसं./Pan/Gir No. Abspb-1568-P (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Shri Ashwani Kumar, Ms. Deepali Aggarwal Ms. Muskan Garg (Cas) –Ld. Ars ""थ"कीओरसे/Respondent By : Sh. Charan Dass (Addl. Cit) – Ld. Sr. Dr

For Appellant: ShriFor Respondent: Sh. Charan Dass (Addl. CIT) – Ld. Sr. DR

Section 143(3)Section 147Section 148Section 2Section 2(22)(e)Section 250(6)Section 69

erred in sustaining l/3rd of addition of Rs. 287083/- made by the Id. Assessing Officer who treated the income of Rs. 287083/- out of agricultural income of Rs.18,00,000/- as income from other sources without any basis. 6. That the appellant craves to add, amend or alter any ground ... same do not form subject matter of present appeal before us. The third addition was on account of agricultural income of Rs.18 Lacs as shown by the assessee. The net agricultural income as shown by the assessee was Rs.38.50 Lacs in support of which the assessee furnished J-Forms

Maganbhai Bahecharbhai Patel, Vadodara vs. Income Tax Officer Ward 1(2)(1), Vadodara

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

ITA 834/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad07 Aug 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri Niraj Surti, ARFor Respondent: Shri Prateek Sharma, Sr DR

Section 115BSection 234ASection 234FSection 69A

dismissing the appeal and thereby upholding an addition of Rs. 15,00,000/- u/s 69A as unexplained money which as such is an agricultural income not liable to tax and which deserves to be deleted. Maganbhai B Patel Vs. ITO Asst. Year : 2018-19 - 2– 2. In the facts ... circumstances of the case, Ld. CIT(Appeals), NFAC has erred in law and in facts in treating the cash deposit of agricultural income of Rs.6,97,860/- already accepted by him as such as unexplained income liable to tax u/s 115BBE. 3. In the facts and circumstances of the case

Bheru Lal Kumawat, Vill Kulthana vs. ITO Pratapgarh, Pratapgarh

In the result, the appeal of the assessee is allowed

ITA 1288/JPR/2024[2016-17]Status: DisposedITAT Jaipur06 Aug 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Tarun Mittal, CAFor Respondent: Sh. Gautam Singh Choudhary, Addl. CIT

Section 143(2)Section 143(3)

Oriental Bank Total 3100200.00 2900000.00 -200200.00 2. The Ld. AO has erred in estimating the Agriculture income without appreciating the and Ld. actual sales invoices and also estimated Expenditure on very high side CIT(A) has erred in confirming the additions of Rs 7,26,969/- being Agriculture income ... addition of Rs.29,68,200/- and Rs.7,26,969/- on allegation of cash deposit in bank account on protective basis and disallowance of agricultural income alleging from undisclosed sources respectively, when as per notice issued under CASS, the only reason for selection in scrutiny was “Return filed after

Maharawal Khewaji Trust, Faridkot vs. DCIT, C-1 (E), Chandigarh

In the result, Assessee’s appeal is dismissed

ITA 569/CHANDI/2019[2015-16]Status: DisposedITAT Chandigarh06 Aug 2025AY 2015-16

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 569/Chd/2019 "नधा"रण वष" / Assessment Year : 2015-16 Maharawal Khewaji Trust Dcit, C/O J K Gupta, ] बनाम Circle 1 Advocate, (Exemption), Vs. 4702, Hospital Bazar, Chandigarh. Bathinda. "थायी लेखा सं./Pan No: Aaatm2875R अपीलाथ"/Appellant ""यथ"/Respondent ( Virtual Hearing ) "नधा"रती क" ओर से/Assessee By : None राज"व क" ओर से/ Revenue By : Smt Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 14.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 06.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 15.02.2019 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

For Appellant: NoneFor Respondent: Smt Kusum Bansal, CIT DR

Section 12ASection 70

Bathinda. 5. That on the facts and circumstances of the case and in law, the learned CIT(A) should not have treated the agricultural income for rate purposes being a case of charitable society. That on the facts and circumstances of the case 6. and in law, the learned

Kasireddy Sasikalamma, Nellore vs. ITO., Ward -1, Gudur

ITA 225/HYD/2025[2017-18]Status: DisposedITAT Hyderabad06 Aug 2025AY 2017-18

Bench: Us:

For Appellant: NoneFor Respondent: Shri Helen Ruby Jesindha

Section 147Section 148Section 68Section 69ASection 69BSection 69C

appreciated that there is no expense claimed or booked by the Appellant in this regard and it is merely drawing from the business accounts. Agricultural Income Disallowed-Rs. 1,35,000/--No Speaking Order or Basis: (xiv) The Learned AO/CIT(A) ought to have noted that that the Appellant ... money u/s 69B Rs.13,90,000/- 3 Unexplained money u/s 68 Rs.32,605/- 4 Drawing as unexplained Rs.1,55,700/- expenditure u/s 69C 5 Agricultural income (no evidence Rs.1,35,000/- submitted for the agricultural income and expenses) 4. Aggrieved, the assessee carried the matter in appeal before

Karuppusamy Jayaprakash, Coimbatore vs. Income Tax Officer, Coimbatore

ITA 229/CHNY/2025[2019-20]Status: DisposedITAT Chennai06 Aug 2025AY 2019-20

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.229/Chny/2025

Section 131Section 132Section 269SSection 271D

taken or accepted and the person by whom the loan or deposit or specified sum is taken or accepted, are both having agricultural income and neither of them has any income chargeable to tax under this Act: 54[Provided also that the provisions of this section shall have effect

Prema Kumari, Bangalore vs. Income Tax Officer, Ward-2(2)(1), Bangalore

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

ITA 89/BANG/2025[2012-13]Status: DisposedITAT Bangalore05 Aug 2025AY 2012-13

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheetal, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)

Section 2(13)Section 2(14)

lack of supporting evidence. However, in the remand report, the AO accepted that the income arose from agricultural operations and recommended treating it as agricultural income. Hoever, the ld. CIT(A) still sustained the AO’s original addition. 13. Being aggrieved by the order of learned CIT-A, the assessee ... later assessment year (A.Y. 2015–16) in ITA 75/Bang/2025, this very Bench of the Tribunal has accepted similar income from the same party as agricultural income. Therefore, following the rule of consistency, we find merit in the claim of the assessee. Accordingly, we direct the AO to delete the addition

Prema Kumari, Bangalore vs. ACIT, Circle-4(3)(1), Bangalore

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

ITA 75/BANG/2025[2015-16]Status: DisposedITAT Bangalore05 Aug 2025AY 2015-16

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Sheetal, AdvocateFor Respondent: Shri Subramanian S, JCIT (DR)

Section 2(13)Section 2(14)

Dalsukhbhai Jivrajbhai Savalia, Liliya Mota vs. ITO WD 3(1)(4), Rajkot-Amreli, Amreli

In the result, the assessee’s appeal is partly allowed, in above terms

ITA 188/RJT/2025[2017-18]Status: DisposedITAT Rajkot04 Aug 2025AY 2017-18

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Mehul Ranpura, ARFor Respondent: Shri Dheeraj Kumr Gupta, Sr-DR

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 250Section 69A

done by the assessee, which was subsequently redeposited during the demonetization period. The assessee was also holding some agricultural land and also earned agricultural income apart from regular business income, for the year under consideration, the assessee has shown khetiwadi income of Rs.4,19,040/-. Thus, from the facts ... record. Learned Counsel for the ITA No. 188/RJT/2025 (AY:17-18) as Dalsukhbhai J Savalia ‘@) assessee, argued that assessee has submitted proof of agricultural income earned, cashbook showing opening cash and subsequent realization of cash up to the demonetization period, copies of bank statements, bills for agriculture produces sold, affidavit

K.K.Radhakrishnan, Kannur vs. DCIT, Kozhikkode

ITA 520/COCH/2023[2012-13]Status: DisposedITAT Cochin04 Aug 2025AY 2012-13

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Arun Raj S, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR

Section 132Section 153ASection 153DSection 69C

21/06/2013. The return of income for the A.Y. 2007-08 was filed on 05/08/2013 declaring income of Rs.3,10,370/- and agricultural income of Rs. 1,46,327/-. 5. Against the said return of income, assessment was completed by the AO at a total income

K.K.Radhakrishnan, Kannur vs. DCIT, Kozhikkode

In the result, appeal of the assessee is dismissed

ITA 519/COCH/2023[2010-11]Status: DisposedITAT Cochin04 Aug 2025AY 2010-11

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Arun Raj S, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR

Section 132Section 153ASection 153DSection 69C

Kk Radhakrishnan, Kannur vs. DCIT Central Circle 2, Kozhikode

ITA 518/COCH/2023[2009-10]Status: DisposedITAT Cochin04 Aug 2025AY 2009-10

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Respondent byFor Respondent: Shri Arun Raj S, Advocate

Section 132Section 153ASection 153DSection 69C

Kk Radhakrishnan, Kannur vs. DCIT Central Circle 2, Kozhikode

ITA 517/COCH/2023[2007-08]Status: DisposedITAT Cochin04 Aug 2025AY 2007-08

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Arun Raj S, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR

Section 132Section 153ASection 153DSection 69C

The ACIT Central Circle -2, Kozhikode vs. M/S Kk Builders, Kannur

In the result, appeal filed by the Revenue stands allowed for statistical purposes and the cross objection filed by the assessee stands dismissed

ITA 444/COCH/2023[2013-14]Status: DisposedITAT Cochin04 Aug 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Acit, Central Circle-2, .... Appellant Kozhikode Vs. M/S. K.K. Builders, .... Respondents P P V , 526F, Peravoor, Kannur. [Pan : Aadfk 0068 K] C.O.No. 05/Coch/2023 (Arising Out Of Ita No. 444/Coch/2023) (Assessment Year : 2013-14) M/S. K.K. Builders, .... Applicant P P V , 526F, Peravoor, Kannur. [Pan : Aadfk 0068 K] Vs. Acit, Central Circle-2, .... Respondent Kozhikode

For Appellant: Shri Arun Raj S, AdvocateFor Respondent: Shri Suresh Sivanandan, CIT-DR

Section 132Section 153Section 153B

foreign liquor (IMFL). The return of income for the year under consideration was filed on 05/08/2013 declaring income of Rs.9,77,74,968 and agricultural income of Rs. 89,756/-. Against the said return of income, assessment was completed by Dy.Commissioner of Income Tax, Central Circle-II, Kozhikode (for short

Kiran Nimba Bramhankar, Nashik vs. Income Tax Assessment Unit (NFAC), Delhi

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

ITA 1290/PUN/2025[2015-16]Status: DisposedITAT Pune04 Aug 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1290/Pun/2025 धििाारण वर्ा / Assessment Year: 2015-16 Kiran Nimba Bramhankar, Income Tax Jaikheda 422, Nashik- Assessment Unit 423303 Vs. (Nfac), Delhi Maharashtra Pan-Axepb5967G अपीलार्थी / Appellant प्रत्यर्थी/Respondent Assessee By: Ca Sarvesh V Toshniwal Department By: Shri Ramnath P Murkunde Date Of Hearing: 04-08-2025 Date Of 14-08-2025 Pronouncement:

For Appellant: CA Sarvesh V ToshniwalFor Respondent: Shri Ramnath P Murkunde

Section 142(1)Section 144Section 147Section 148Section 250

affirmation of an incorrect addition as unexplained income of Rs. 40,91,000/- in Bank of Maharashtra (Jayakhede Branch) since it is an agricultural income and the appellant has documentary evidence for the same. Ground 6- The Ld CIT(A)'s rejection of delay condonation has led to the affirmation ... have heard rival contentions and perused the record placed before us. The assessee is an individual and claimed to be an Agriculturist having agricultural income from the land situated at Jaikheda, Taluka-Baaglaan, District-Nashik. Based on the information above cash deposits of Rs. 81,41,700/- and other contractual

Jaikusuma Balakrishna Shetty, Bangalore vs. Income Tax Officer, Ward-1(2)(2), Bangalore

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

ITA 1096/BANG/2025[2016-17]Status: DisposedITAT Bangalore04 Aug 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Shri Waseem Ahmedassessment Year : 2016-17

For Appellant: Ms. Sunaina Bhatia, Ld.CAFor Respondent: Sri Balasamy N – Ld.JCIT

Section 143(3)Section 154Section 234Section 250

justified in upholding the addition of Rs.51,85,500/- towards alleged bogus bills treated as income from other sources, while accepting the agricultural income reported by the appellant under the facts and in the circumstances of the appellant's case. 4.2 The learned CIT[AJ/NFAC is not justified in upholding ... addition of Rs. 19,28,944/- towards proportionate expenditure on alleged bogus bills treated as income from other sources, while accepting the agricultural income reported by the appellant under the facts and in the circumstances of the appellant's case. 5. Without prejudice to the right to seek waiver with

Late Shri. Kasam Nurmad Karadiya, Jogeshwari, Mumbai vs. Income Tax Officer, Ward 41(4)(2), Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 2069/MUM/2025[2012-13]Status: DisposedITAT Mumbai04 Aug 2025AY 2012-13

Bench: Shri Saktijit Dey & Shri Prabhash Shankarlate Shri Kasam Nurmad V/S. Income Tax Officer, Ward – Karadiya बनाम 41(4)(2), Kautilya Bhavan, (Through His Legal Heir Shri Rahemtullah Kasambhai Avenue 3, Near Videsh Karadiya) 804, Anand Co-Op Bhavan, G Block Bkc, Hsg Society, Behram Baug Bandra Kurla Complex, Road, Jogeshwari West, Bandra (East), Mumbai – Mumbai–400102, Maharashtra 400051, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aahpk5855E Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: None. Paper book on recordFor Respondent: Shri Hemanshu Joshi, Sr. DR

Section 143(3)Section 27Section 54F

same infact being one single residential house. 8. The Hon’ble CIT(A) has erred in treating an amount of Rs. 21,642/- being agricultural income as income from other sources without appreciating the facts of the case as well as law. 9. The Hon’ble CIT(A) has erred ... Late Shri Kasam Nurmad Karadiya from other sources, consequently resulting into disallowance of deduction claimed u/s 54F of the Act and treating the agriculture income of Rs. 21,642/- too as Income from other sources. 6. Against the said assessment order, assessee filed an appeal before