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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

Faizan Ahmad, Dehradun vs. Pr.CIT, Dehradun

Appeal is allowed

ITA 821/DEL/2021[2015-16]Status: DisposedITAT Delhi11 Feb 2026AY 2015-16

Bench: Sh. Satbeer Singh Godara & Sh. Naveen Chandraita No. 821/Del/2021 : Asstt. Year: 2015-16 Faizan Ahmad, Vs Pcit, Verendra Kalra & Co., Cas, Dehradun-248001 75/7, Rajpur Road, Dehradun-248001 (Appellant) (Respondent) Pan No. Acbpa6844R Assessee By : Ms. Ruchika Rana, Adv. Revenue By : Ms. Monika Singh, Cit-Dr Date Of Hearing: 11.02.2026 Date Of Pronouncement: 11.02.2026 Order Per Satbeer Singh Godara: This Assessee’S Appeal For Assessment Year 2015-16 Arises Against The Pcit, Dehradun’S Din & Order No. Itba/Rev/F/Rev5/2020-21/1031618340(1) Dated 19.03.2021, In Proceedings U/S 263 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Ms. Ruchika Rana, AdvFor Respondent: Ms. Monika Singh, CIT-DR
Section 263

erroneous 2 Faizan Ahmad one, since having not carried out the necessary detailed enquiries regarding land advance(s) received to Rs.75,00,000/- and agricultural income, involving varying sums, respectively. 4. It is in this factual backdrop that we notice from the learned PCIT’s revision order itself at page ... limited” scrutiny inter alia regarding the twin issues of mismatch in sales turnover and substantial increase in capital than that of advances received and agricultural income (supra). That being the case, we are of the considered view in this factual backdrop that once the Assessing Officer could not have travelled

Shri Kamlesh Vashrambhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 65/RJT/2014[2010-11]Status: DisposedITAT Rajkot10 Feb 2026AY 2010-11

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No.451/Rjt/2013 (Assessment Years: (2008-2009) Shri Vashrambhai Ghelabhai Ramani, Vs. The Dcit, 22, Ranchodnagar Society, Kuvadava Central Circle-2, Road, Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bflpr5056N आयकर अपील सं./Ita Nos.65/Rjt/2014 (Assessment Years: (2010-11) & आयकर अपील सं./Ita Nos. 63/Rjt/2014 &407/Rjt/2014 (Assessment Year: 2011-2012) Shri Kamlesh Vashrambhai Ramani, Deputy Commissioner Of Income-Tax, Prop. Marutinandan Petroleum, 22, Vs. Central Circle-2, Ranchodnagar Society,Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahqpr2043D

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR
Section 132Section 143(3)Section 153ASection 271A

receipt of the notice. The return of income showing total Income of Rs. Nil was filed on 31.01.2012. The assessee has also shown agricultural income of Rs 10,73,608/-. A notice u/s 143(2) of the Act, was issued on 29.08.2012, which was served upon the assessee. Further detailed ... which are reproduced by the AO, at page no.3 to 4 of the assessment order. In reply, the assessee submitted that assessee had agriculture income and out of agriculture income amount of Rs.21,50,000/- was given to Manojbhai Arjanbhai Nandasana. The assessee also submitted that he does not carry

Shri Kamlesh Vashrambhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 63/RJT/2014[2011-12]Status: DisposedITAT Rajkot10 Feb 2026AY 2011-12

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No.451/Rjt/2013 (Assessment Years: (2008-2009) Shri Vashrambhai Ghelabhai Ramani, Vs. The Dcit, 22, Ranchodnagar Society, Kuvadava Central Circle-2, Road, Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bflpr5056N आयकर अपील सं./Ita Nos.65/Rjt/2014 (Assessment Years: (2010-11) & आयकर अपील सं./Ita Nos. 63/Rjt/2014 &407/Rjt/2014 (Assessment Year: 2011-2012) Shri Kamlesh Vashrambhai Ramani, Deputy Commissioner Of Income-Tax, Prop. Marutinandan Petroleum, 22, Vs. Central Circle-2, Ranchodnagar Society,Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahqpr2043D

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR
Section 132Section 143(3)Section 153ASection 271A

receipt of the notice. The return of income showing total Income of Rs. Nil was filed on 31.01.2012. The assessee has also shown agricultural income of Rs 10,73,608/-. A notice u/s 143(2) of the Act, was issued on 29.08.2012, which was served upon the assessee. Further detailed ... which are reproduced by the AO, at page no.3 to 4 of the assessment order. In reply, the assessee submitted that assessee had agriculture income and out of agriculture income amount of Rs.21,50,000/- was given to Manojbhai Arjanbhai Nandasana. The assessee also submitted that he does not carry

Kamlesh Vashrambhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Central Circle-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 407/RJT/2014[2011-12]Status: DisposedITAT Rajkot10 Feb 2026AY 2011-12

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No.451/Rjt/2013 (Assessment Years: (2008-2009) Shri Vashrambhai Ghelabhai Ramani, Vs. The Dcit, 22, Ranchodnagar Society, Kuvadava Central Circle-2, Road, Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bflpr5056N आयकर अपील सं./Ita Nos.65/Rjt/2014 (Assessment Years: (2010-11) & आयकर अपील सं./Ita Nos. 63/Rjt/2014 &407/Rjt/2014 (Assessment Year: 2011-2012) Shri Kamlesh Vashrambhai Ramani, Deputy Commissioner Of Income-Tax, Prop. Marutinandan Petroleum, 22, Vs. Central Circle-2, Ranchodnagar Society,Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahqpr2043D

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR
Section 132Section 143(3)Section 153ASection 271A

receipt of the notice. The return of income showing total Income of Rs. Nil was filed on 31.01.2012. The assessee has also shown agricultural income of Rs 10,73,608/-. A notice u/s 143(2) of the Act, was issued on 29.08.2012, which was served upon the assessee. Further detailed ... which are reproduced by the AO, at page no.3 to 4 of the assessment order. In reply, the assessee submitted that assessee had agriculture income and out of agriculture income amount of Rs.21,50,000/- was given to Manojbhai Arjanbhai Nandasana. The assessee also submitted that he does not carry

Shri Vashrambhai Ghelabhai Ramani, Rajkot-Gujarat vs. The Deputy Commissioner of Income Tax, Cen.Cir.-2, Rajkot-Gujarat

In the result, appeal filed by the assessee, (in ITA No

ITA 451/RJT/2013[2008-09]Status: DisposedITAT Rajkot10 Feb 2026AY 2008-09

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinhaआयकर अपील सं./Ita No.451/Rjt/2013 (Assessment Years: (2008-2009) Shri Vashrambhai Ghelabhai Ramani, Vs. The Dcit, 22, Ranchodnagar Society, Kuvadava Central Circle-2, Road, Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Bflpr5056N आयकर अपील सं./Ita Nos.65/Rjt/2014 (Assessment Years: (2010-11) & आयकर अपील सं./Ita Nos. 63/Rjt/2014 &407/Rjt/2014 (Assessment Year: 2011-2012) Shri Kamlesh Vashrambhai Ramani, Deputy Commissioner Of Income-Tax, Prop. Marutinandan Petroleum, 22, Vs. Central Circle-2, Ranchodnagar Society,Rajkot. Rajkot. "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Ahqpr2043D

For Appellant: Shri Samir Bhuptani, ARFor Respondent: Shri Sanjay Kumar, CIT- DR
Section 132Section 143(3)Section 153ASection 271A

receipt of the notice. The return of income showing total Income of Rs. Nil was filed on 31.01.2012. The assessee has also shown agricultural income of Rs 10,73,608/-. A notice u/s 143(2) of the Act, was issued on 29.08.2012, which was served upon the assessee. Further detailed ... which are reproduced by the AO, at page no.3 to 4 of the assessment order. In reply, the assessee submitted that assessee had agriculture income and out of agriculture income amount of Rs.21,50,000/- was given to Manojbhai Arjanbhai Nandasana. The assessee also submitted that he does not carry

Shri Jamnadas Virjibhai Bhalodia, Rajkot vs. The ITO, Ward- 1 (1) (2), Rajkot

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

ITA 182/RJT/2024[2017-18]Status: DisposedITAT Rajkot09 Feb 2026AY 2017-18

Bench: Dr. Arjun Lal Sainiआयकरअपील सं. /Ita No.182/Rjt/2024 िनधा"रण वष"/Assessment Year : 2017-18 बनाम/ Shri Jamnadas Virjibhai Bhalodia Income Tax Officer B-602, Pentagon Tower, Opp. Vs Ward – 1(1)(2), Rajkot Speedwell Party Plot, Behind Govani Chhatralay, Rajkot, Gujarat - 360005 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Afzpb6922N (अपीलाथ"/Appellant) (""थ"/Respondent) िनधा"रती की ओर से/Assessee By : Shri Mehul Ranpura, Ld. Ar राज"की ओर से / Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 22/01/2026 घोषणा की तारीख/Date Of Pronouncement : 09/02/2026 आदेश/Order Per, Dr. Arjun Lal Saini, A.M:

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 69A

details. In response to this notice, the assessee filed e-submission/s as called for during the course of assessment proceedings. The assessee earned agricultural income and income from other sources during the year under consideration. As per the SFT account summary details, the assessee has deposited cash ... source of cash deposits is out of cash withdrawals made in earlier years and current year, cash on hand and loans received and agricultural income. However, the contention of the assessee did not appear acceptable by the assessing officer, therefore, a show -cause notice dated 10.12.2019 was issued

Narottam Atmaram Warde, Raigad vs. Income Tax Officer, Panvel

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

ITA 3139/PUN/2025[2012-13]Status: DisposedITAT Pune09 Feb 2026AY 2012-13

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.3139/Pun/2025 निर्धारण वषा / Assessment Year: 2012-13 Narottam Atmaram Warde, V The Income Tax Koproli, Saral, Alibag, Dist- S Officer, Raigad – 402209. Panvel. Pan: Abypw5023A Appellant/ Assessee Respondent /Revenue Assessee By Shri Ronak Jain Revenue By Shri Ajitesh Kumar Meena – Addl.Cit Date Of Hearing 29/01/2026 Date Of Pronouncement 09/02/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2012-13 Dated 08.08.2024 Emanating From The Assessment Order Passed Under Section 144 R.W.S 147 Of The I.T.Act, Dated 13.12.2019. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Leamed Commissioner Of Income Tax (Appeals) Erred In Interpreting Law & Facts In Dismissing The Appeal For Non-Prosecution

Section 144Section 2(14)Section 2(14)(iii)Section 250Section 250(6)

determine the nature of land. Honourable Bombay High Court in CIT v. Debbie Alemao 331 ITR 59 (Bom HC) held that "Actual earning of agricultural income is not a sine qua non for determining the character of agricultural land." Absence of agricultural income is legally irrelevant. The AO has implicitly ... assumed that because no agricultural income was shown, the land is not agricultural. This assumption is unsustainable in law. 2.3 Even if the land was later used for development, the law is settled that what matters is the character of land on the date of transfer, not future use. Honourable