“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

Phi Seeds Pvt. Ltd., Hyderabad vs. DCIT, Circle- 19(2), New Delhi

In the result, the appeal of the Assessee is allowed

ITA 7655/DEL/2017[2012-13]Status: DisposedITAT Delhi28 Jan 2026AY 2012-13

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumar

For Appellant: Sh. Ajay Vohra, Sr. Adv., Sh. Aditya VohraFor Respondent: Ms. Monika Singh, CIT(DR)

Section 10(1)Section 143Section 143(3)Section 144CSection 144C(15)Section 92C

assessing the income at Rs. 128,32,21,949/- after addition of Rs. 100,87,51,183/- as business income as against exempt agricultural income claimed by the assessee u/s. 10(1) of the Act and income from other sources. Against the above, assessee preferred the appeal before ... impugned order dated 03.10.2017 by following his predecessor’s order in earlier years where assessee company’s claim of exemption u/s. 10(1) for agricultural income is not allowable, as assessee is deriving income from manufacturing / processing and sale / purchase of hybrid seeds and income claimed as agricultural income

Shree Pragati Co Op Credit Society Limited, Rajkot vs. ITO, Ward-2(1)(1), Rajkot

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

ITA 693/RJT/2025[2020-21]Status: DisposedITAT Rajkot27 Jan 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Sanjay Pungalia Ld. CIT (DR)

Section 143(2)Section 143(3)Section 44ASection 68Section 80P

Limited scrutiny’ on the ground of high Liabilities as compared to low income/receipts. It is further stated that low income (including exempt income and agricultural income) in comparison to high loans/advances/investment in shares appearing in balance sheet and large deduction under chapter VI-A of the Act. On which further

Chaturbhai K. Detroja (HUF), Morbi vs. Income Tax Officer Ward-1, Morbi

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

ITA 884/RJT/2024[2017-18]Status: DisposedITAT Rajkot27 Jan 2026AY 2017-18

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Vimal Desai, 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

filed his return of income for assessment year (A.Υ.) 2017-18 on 20.03.2018, declaring therein total income of Rs.4,330/- and agricultural income of Rs.2,42,046/-. The return of income was processed u/s 143(1) of the Act. Later on, the case of the assessee was selected through ... assessee in his reply submitted before the assessing officer, regarding the source of cash deposit during demonetization, stating that earlier withdrawals and agricultural income were the main source to deposit cash in the bank account. The assessee is engaged in agricultural activities. The Assessee's primary source of income

Ramanbhai P. Viradiya HUF, Surat vs. ITO, Ward 3(3)(1), Surat

In the result, the appeal of the assessee is allowed

ITA 556/SRT/2025[2017-18]Status: HeardITAT Surat23 Jan 2026AY 2017-18

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

For Appellant: Shri Mehul Shah, C.AFor Respondent: Shri Ashish Kumar, Sr. D.R

Section 68

order dated 27-09-2024 passed by National Faceless Appeal Centre (NFAC), Delhi for assessment year 2017-18. 2. The assessee has shown agricultural income at Rs. 1,87,925/-. The assessee’s case was selected for limited scrutiny to verify the cash deposit during demonetization period. The Assessing Officer

Sureshbhai Popatlal Patel L/H Sohankumar Sureshkumar Patel, Vapi vs. ITO, Ward 8, Vapi

In the result, the appeal of the assessee is allowed

ITA 1337/SRT/2024[2007-08]Status: HeardITAT Surat23 Jan 2026AY 2007-08

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

Section 147Section 250Section 69A

earlier years’ savings. Regarding the addition of Rs. 1,96,000/- on account of cash deposits, it is submitted that the same represents agricultural income; to Sureshbhai Popatlal Patel LH Sohankr S Patel vs. ITO Asst. Year : 2007-08 - 3– substantiate the claim the copies of 7/12 land records were ... assessee. . No material has been brought on record by the Revenue before us to controvert the claim that the deposits emanated from agricultural income. In the absence of any contrary evidence, the explanation offered by the assessee deserves acceptance. Sureshbhai Popatlal Patel LH Sohankr S Patel vs. ITO Asst. Year

Bhikubhai Parsottambhai Patel, Valsad vs. Income Tax Officer, Ward-1, Valsad

In the result, the appeal of the assessee is allowed

ITA 493/SRT/2025[2011-12]Status: HeardITAT Surat22 Jan 2026AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamblebhikubhai Parsottambhai Patel, Income Tax Officer, Vs. Ap Tigra, Ward-1, Valsad, Valsad. Valsad-396001. [Pan : Aqnpp9198 F] (Appellant) .. (Respondent) Appellant By : Shri Biren Shah, Ar Respondent By: Shri Ashish Kumar, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 22.01.2026 O R D E R Per Dr. B.R.R. Kumar, Vice-:- The Captioned Appeal Has Been Filed By The Assessee Against The Order Dated 28.02.2025 Passed By The Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“The Cit(A) In Short), Under Section 250 Of The Income-Tax Act, 1961 (“The Act”), Relating To The Assessment Year 2011-12. 2. The Assessing Officer Made An Addition Of Rs.10,48,000/- As Unexplained Cash Deposits In The Bank Account Of The Assessee. The Assessee Filed The Return Of Income Declaring Total Income Of Rs.30,130/- Along With Agricultural Income Of Rs.8,65,740/-. It Was Submitted Before The Ld. Cit(A) That The Assessee Had Furnished Details Of Sale Of Agricultural Produce, Which Are As Under:

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Ashish Kumar, Sr. DR

Section 250

cash deposits in the bank account of the assessee. The assessee filed the return of income declaring total income of Rs.30,130/- along with agricultural income of Rs.8,65,740/-. It was submitted before the Ld. CIT(A) that the assessee had furnished details of sale of agricultural produce, which ... under: The appellant, Shri Bhikubhai P. Patel, furnished copies of sale bills and sales ledger in support of the agricultural income stated to have been earned during the financial year 2010-11. From the same, it appears that the assessee received the following amounts towards sale of agricultural produce from

Suresh Kumar, Manas Bhawan, Rnt Marg, Indore vs. ITO, Burhanpur, Indore

In the result we are of the considered

ITA 369/IND/2025[2013-14]Status: DisposedITAT Indore22 Jan 2026AY 2013-14

Bench: Shri B.M. Biyani & Shri Paresh M Joshisuresh Kumar, Ito –Burhanpur. बनाम/ 112, Manas Bhawan, Vs. 11 Rnt Marg, Indore (Pan: Eekps7728B) (Appellant) (Respondent) Assessee By Shri Pankaj Shah & Soumya Bumb, Cas Revenue By Shri Ashish Porwal, Sr.Dr Date Of Hearing 13.01.2026 Date Of 22.01.2026 Pronouncement आदेश/ O R D E R

Section 133(6)Section 139(1)Section 142(1)Section 147Section 148Section 250Section 253Section 69A

submitted at the time of hearing. In the grounds of appeal, the appellant claimed that the cash deposited into the bank account was agricultural income. It is for these reasons, several notices were issued by giving ample opportunities to the appellant to substantiate the grounds raised in the appeal memo ... responded to all those notices, it is evident that the claim of the appellant that cash deposited into the bank account was out of agricultural income was not acceptable. Hence, the addition of Rs.65,36,100/- made as unexplained money is upheld. Further, the addition of Rs.2

Suyojit Garden, Nashik vs. The Income-Tax Officer, Ward 2(1), Nashik

In the result, appeal of the assessee is dismissed

ITA 2206/PUN/2025[2012-13]Status: DisposedITAT Pune22 Jan 2026AY 2012-13

Bench: Dr. Manish Boradआयकर अपील सं./Ita No.2206/Pun/2025 धििाारण वर्ा / Assessment Year: 2012-13 Vs Ito, Ward - Suyojit Garden, F-1/2, Suyojit Height, 2(1), Nashik Opp. Rajiv Gandhi Bhavan, Sharanpur Road, Nashik-422002 Maharashtra Pan-Abdfs6680A Appellant Respondent

For Appellant: NoneFor Respondent: Shri Vishwajit Shinde

Section 10(1)Section 143(2)Section 143(3)Section 250Section 801BSection 801B(10)Section 80I

justified in not considering the impugned income of Rs. 10,00,000/- eamed by the appellant on account of sale of lawns as agricultural income. 6.2 dated 27.03.2019 in support of this ground of appeal. Relevant part of the submission During the appellate proceedings the appellant made submissions vide letter ... above ground of appeal, the sale of lawns of Rs. 10,00,000/- or as the case may be income therefrom is the agricultural income for the appellant firm, which is also exempt u/s 10(1), Therefore, without prejudice, the A.O. may be directed to treat the income from producing

Deputy Commissioner of Income Tax, Central Cirlce-1(4), Chennai vs. Ramanathan Viswanathan, Chennai

ITA 1597/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

tribunal has found that with regard to cash and jewellery, the explanation of the assessee was that he had agricultural properties and derived agricultural income. That income was utilised to acquire jewellery that was belonging to him and his family. With regard to cash stated to be recovered from

Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai vs. Ramanathan Viswanathan, Chennai

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1556/CHNY/2025[2016]Status: DisposedITAT Chennai22 Jan 2026

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

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1324/CHNY/2025[2017-18]Status: DisposedITAT Chennai22 Jan 2026AY 2017-18

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1323/CHNY/2025[2016-17]Status: DisposedITAT Chennai22 Jan 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1321 To 1324/Chny/2025 िनधारण वष/Assessment Years: 2014-15 To 2017-18 R. Viswanathan, Flat No.A-4, Rams Anjali Atrium No.8, Sundaram Salai, R.A. Puram, Chennai-600 028. [Pan: Adlpv 6760 G] V. The Dcit, Central Circle-1(4), Chennai. (अपीलाथ/Appellant) (यथ/Respondent) आयकर अपील सं./Ita Nos.1556 & 1597/Chny/2025 िनधारण वष/Assessment Years: 2016-17 & 2015-16 The Dcit, Central Circle-1(4), Chennai. V. R. Viswanathan, Flat No.A-4, Rams Anjali Atrium No.8, Sundaram Salai, R.A. Puram, Chennai-600 028. [Pan: Adlpv 6760 G] (अपीलाथ/Appellant) : (यथ/Respondent) अपीलाथ की ओर से/ Assessee By : Shri. V. Naga Prasad, Advocate/Ar थ की ओर से /Department By : Smt. E. Pavuna Sundari, Cit/Dr सुनवाईकतारीख/Date Of Hearing : 29.10.2025 / 17.11.2025 घोषणाकतारीख /Date Of Pronouncement : 22.01.2026 :: 2 ::

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1322/CHNY/2025[2015-16]Status: DisposedITAT Chennai22 Jan 2026AY 2015-16

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

R.Viswanathan, Chennai vs. The Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai

ITA 1321/CHNY/2025[2014-15]Status: DisposedITAT Chennai22 Jan 2026AY 2014-15

For Appellant: Shri. V. Naga PrasadFor Respondent: Smt. E. Pavuna Sundari

Section 132Section 139Section 142(1)Section 153ASection 153CSection 250

Yogendra Singh, Fatehgarh vs. Income Tax Officer 4(2)(1), Farrukhabad

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

ITA 524/AGR/2025[2017-18]Status: DisposedITAT Agra21 Jan 2026AY 2017-18

Bench: Shri M. Balaganeshyogendra Singh, Vs. Income Tax Officer, Nekpur Kalan Fatehgarh, Ward-4(2)(1), Farrukhabad, Up Farrukhabad (Appellant) (Respondent) Pan: Eqrps5224K Assessee By : Shri Rajendra Sharma, Adv Shri Manuj Sharma, Adv Revenue By: Shri Anil Kumar, Sr. Dr Date Of Hearing 21/01/2026 Date Of Pronouncement 21/01/2026

For Appellant: Shri Rajendra Sharma, AdvFor Respondent: Shri Anil Kumar, Sr. DR

Section 144Section 69A

agricultural land. The assessee, along with his three brothers, were undertaking the cultivation of the lands belonging to the father, from where they earned agricultural income, which were equally divided between them. During the year under consideration, pursuant to the announcement of demonetization by the Government of India, the cash ... fact of those lands being used for agricultural operations by way of cultivation by his four sons and also the fact that the agricultural income so derived is being divided by his four sons. The assessee also filed a confirmatory letter of Gram Pradhan, confirming the facts and also confirming

Shri Pramodbhai Bhikubhai Desai, Valsad vs. I.T.O Ward -7, Vapi

In the result, the appeal of the assesse is allowed

ITA 510/SRT/2025[2011-12]Status: HeardITAT Surat21 Jan 2026AY 2011-12

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

For Appellant: Shri Rajesh Upadhyay, A.RFor Respondent: Shri Ashish Kumar, Sr. D.R

appeal of the assessee thereby confirming the addition to the extent of Rs. 21,30,000/-. The source of the cash deposited through agricultural income shown before the A.O. as well as before the CIT(A). In fact, the assessee has given the details of payment

Ramesh Kumar Singh, Surat vs. ITO, Ward 1(2)(5), Surat

In the result, the appeal of the assessee is allowed

ITA 1216/SRT/2024[2014-15]Status: HeardITAT Surat21 Jan 2026AY 2014-15

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

For Appellant: Shri PM Jagasheth, CAFor Respondent: Ms. Namita Patel, Sr. D.R

undisclosed investment in immovable property. The assessee submitted before the Assessing Officer that the assessee received gift from his father who is having agricultural income. Since the gift amount was received in Rameshkumar Singh Vs. ITO Asst. Year : 2014-15 - 2– cash, the assessee paid cash. The Assessing Officer ... Officer as well as the CIT(A) proceeded that the assessee did not explain the source of the income of the father which was agricultural income. In fact, the assessee clearly mentioned that the assessee’s father is agriculturist and this fact was not denied by the Assessing Officer. Thus

Amar Nath Singh, Ara vs. ITO, NFAC, Delhi

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

ITA 460/PAT/2025[2017-18]Status: DisposedITAT Patna21 Jan 2026AY 2017-18

Bench: The Itat. In This Regard, The Assessee Has Given Explanation Which Is As Under:

Section 144Section 147Section 148Section 250Section 253(5)

that the assessee is an agriculturist and he does not require to maintain any books of accounts the amount deposited are accumulated out of agricultural income and past savings of family members over the years because of demonetisation the cash 4 Amar Nath Singh maintained were deposited. The assessee

Qadeer Ahmed Mohammed, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

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

ITA 768/HYD/2025[2020-21]Status: DisposedITAT Hyderabad21 Jan 2026AY 2020-21

Bench: SHRI VIJAY PAL RAO, HON’BLE (Vice President), SHRI MANJUNATHA G, HON'BLE (Accountant Member)

Section 142(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 249(2)Section 68

return was processed under Section 143(1)(a) of the Income-tax Act, 1961 on 05.10.2021. The assessee had shown net agricultural income of Rs. 78,65,000/- and also claimed current year loss of Rs. (-)63,30,196/- under the head “Profits & Gains from business or profession”. The assessee ... business of freight transport by road. The case was selected for limited scrutiny under CASS on the reasons of substantial increase in agricultural income as compared to the preceding year, agricultural income (risk analysis), and large agricultural income per acre shown in comparison to the average agricultural income

Abraham Nathaniel Addanki, Hyderabad vs. ITO., Ward-14(1), Hyderabad

ITA 1148/HYD/2025[2016-17]Status: DisposedITAT Hyderabad21 Jan 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1148/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Abraham Nathaniel Vs. Income Tax Officer, Addanki, Ward-14(1), Hyderabad. Hyderabad. Pan: Adqpa7546N

For Appellant: Smt. S. Sandhya, AdvocateFor Respondent: Shri K. Vinoth Kannan

Section 142(1)Section 143(3)Section 144BSection 147Section 148

stated, the assessee had filed his original return of income for AY 2016-17 on 23/02/2017, declaring an income of Rs.4,91,710/- and agricultural income of Rs.72,500/-. Subsequently, the case was selected for scrutiny assessment under CASS to verify “exempt income”. 3. Original assessment was framed ... 144B of the Act, dated 30/03/2022 after making the aforesaid additions, determined the income of the assessee at Rs.1,68,00,508/- along with agricultural income of Rs.72,500/-. 9. Aggrieved, the assessee carried the matter in appeal before the CIT(A). As the assessee, despite having been afforded