Taxation assignment

Topic- Agricultural income

SUBMITTED BY- ATHARVA ALOK SUBMITTED TO-

ENROLLMENT-19FLICDDN01147 MS. Chitvan Agarwal

 Acknowledgement

On this great occasion of successful completion of my assignment

on agricultural income I would like to thank my faculty miss chitvan
Agrawal mam who has guided and assisted me to complete the
assignment. Without his/her support I would not have finished the
assignment within time.

I would also like to take this opportunity to thank my friends and

family members, without them this assignment could not have been
completed in a short duration.
CONTENTS
INTRODUCTION

MEANING

Necessary conditions for income to be Agricultural income

When Agricultural income consists of both Agricultural and non-agricultural income

Computation of Tax on Non-Agricultural Income when Income has Agricultural Income also

Calculation of Tax is done in the following manners

Case Laws

CONCLUSION

Refrences
INTRODUCTION

Agricultural income is any income that is earned from any rent or revenue from a land or a building,
which is used for an agricultural purpose. Agricultural income is exempt from income tax as per
section 10(1) of the Income Tax Act, 1961. The Central Government has not any power in relation to
this, but the State Government can collect agricultural income from other sources. But when
agricultural income can be non-agricultural income

Sec 2(7) of the Income Tax Act defined “assessee” as means a person by whom any tax or any other
sum of money is payable under this Act, and includes—

(a) every person in respect of whom any proceeding under this Act has been taken for the assessment
of his income or assessment of fringe benefits or of the income of any other person in respect of
which he is assessable, or of the loss sustained by him or by such other person, or of the amount of
refund due to him or to such other person

(b) every person who is deemed to be an assessee under any provision of this Act ;

(c) every person who is deemed to be an assessee in default under any provision of this Act[i] ;

Agriculture income is exempt from tax by virtue of Section 10(1). By virtue of Section 2(1A) the
expression Agriculture Income means:

Any rent or revenue derived from land, which is situated in India and is used for agriculture purpose.

Rent or revenue should be derived from land (may be in cash or kind).

The land should be in India.

The land should be for agriculture purpose.

Any income derived from such land by agricultural operations including processing of the agriculture
produce, raised or received as rent-in- kind so as to render it fit for the market or sale of such
products.

Income is attributable to a farmhouse subject to certain conditions.

The building should be occupied by a cultivator (as a landlord or tenant).

He should be in the immediate vicinity of agriculture land.

The building is used as a dwelling house or as a storehouse or other outbuilding.

The land is assessed to land revenue or local rates or alternatively, the land is situated outside “urban
areas” i.e. any area which is comprised within the municipality jurisdiction having a population of not
less than 10,000 persons or within 8 km from the limits of any such municipality.[ii]

Under the provisions of Section 10(1) of the Income Tax Act, agricultural income is freely exempt
from income tax. However, for individuals or HUFs when agricultural income is in excess of 5,000, it
is aggregated with the total income for the purposes of computing tax on the total income in a manner
which results into “no” tax on agricultural income but an increased income tax on the other income.
[iii]

Meaning of Agricultural Income

Agricultural income is defined under Sec. 2(1A) of the Income Tax Act, 1961.

Agricultural income is any rent or revenue by means of cash or in-kind, derived from a land, which is
used for an agricultural purpose and land should be situated in India.

Income from agricultural should be produced by a cultivator or a rent receiver of that produce in-kind,
which can be fit to take that into the market.

The income should be derived from the sale by a cultivator or a rent receiver of that product which is
produced or received by him, no process can be performed other than the process to render it fit for
the market.

Income which is derived from the building should follow some conditions:

The building should be situated in India;

It should be occupied by a cultivator or a receiver of rent-in-kind.

In the connection of the land of a cultivator or a rent receiver, the building required to be as a
dwelling-house, store-house or other outbuildings.

Agricultural Income has been exempted from Income Tax under Sec. 10(1) of the Income Tax Act,
where it has been given that, in computing, the total income of a previous year of a person whose
source of income is agriculture will not fall under the category of total income. The burden of proof
that an income fall under this category is on the assessee.

Sri Ranganatha Enterprises v. CIT [1998] 232 ITR 568 (kar.)

In this case, the Court held that the burden lies on the assessee to prove that the income derived by
him is the agricultural income for which he is claiming an exemption under Sec. 10(1) of the Income
Tax Act.

Necessary conditions for income to be Agricultural income

There are some necessary conditions which are required for income to be Agricultural income –

Income should be derived from land

The very first requirement is the income should be derived from land not from any other assets. Land
can be owned or occupied by a cultivator who produces on that land, or a rent receiver of that
produce. Land can be farming land or a building that should be occupied or owned by a cultivator or a
rent receiver. That building or farmhouse should be on the same land and used as a dwelling-house,
store-house or other outbuildings.

Income should be in the form of rent or revenue,

Rent is payment, it can be in cash or in-kind, by one person to another in respect of a grant of right to
use that land.

Revenue is used in a broader sense, In the case of Durga Narain Singh v. CIT [ (1947) 15 ITR 235]

“Revenue” covers income other than rent. Mutation fees extracted from tenants upon their succeeding
to occupancy holding are revenue derived from land.

Revenue can be derived from land only if lands are an effective and immediate source of income and
not the indirect and secondary source of income. Where income derived from indirect source then it
will not be considered income derived from land.

We can understand this with the help of the case Bacha F. Guzdar v. CIT,

In this case, a dividend paid by a company out of its agricultural income is not revenue derived from
land, as an effective and immediate source of income is shareholding and not the land.

Land must be situated in India

Another condition is the land must be situated in India, whether situated in urban areas or rural areas.
The areas are also mentioned in Sec. 2(1A) of the Income Tax Act. The area where land revenue can
be collected by officers of the government:

If it is situated in an area which comes within the jurisdiction of the municipality or cantonment board
where the population is not less than ten thousand.

Any area within the distance,

Not being more than two kilometers from the local limits of any municipality or cantonment board
and which has a population of more than ten thousand but not exceeding one lakh.

Not being more than six kilometers from the local limits of any municipality or cantonment board and
which has a population of more than one lakh but not exceeding ten lakh.

Not being more than eight kilometers from the local limits of any municipality or cantonment board
and which has a population of more than ten lakh.
Agricultural income from foreign countries will be considered as income from other sources and it
will not be exempted under Agricultural income.

Land must be used for basic operations of Agriculture

For exemption under agricultural income, the operation must be related to agricultural. That means
land should be used for the agricultural purpose.

Now, what can be understood by the term ‘Agricultural Purpose’. In the case of CIT v. Raja Benoy
Kumar Suhas Roy [1957] 32 ITR 466, the Supreme Court laid down the principles in regard to the
term ‘Agriculture’ and ‘Agricultural Purposes’.

SC divided operations into two types-

Basic operation.- Basic operation includes the expenditure of human skill and labor upon the land
itself, merely having an agricultural land will not constitute agricultural purposes. Some operations
like tilling of land, sowing of the seeds, planting, etc.

Subsequent operation.- Subsequent operations are performed after the produce sprouts from the land.
Like weeding (removal of wild plants), digging the soil around the growth, removal of undesirable
undergrowths, removal of the crop from insects and pests, cutting, harvesting, rendering the produce
fit for the market etc.. Subsequent operation must be in continuation of basic operations, mere
performance of these activities on the land will not constitute agricultural operation.

If this integrated activity is done on the land then it can be said to be “Agricultural purposes” and the
income derived from these activities said to be “Agricultural income”.

Agricultural Activity does not merely include the production of foods and grains. It includes all
products from the performance of basic and subsequent operations on land. We can not confine it to
the production of food and grains for human consumption, it can also include products for trade and
commercial assets like cotton, flax, jute, indigo, etc. and it would also include forest products like
timber, sal, tendu leaves, and all those forest products which are used for commercial purpose.

In support of the Agricultural operation, there is another case K. Lakshmanan Co. v. CIT [1999] 239
ITR 597 (SC),

In this case, SC held that Sec. 2(1A)(b) of the Act does not contemplate the sale of commodity
different from what is cultivated and processed and where the assessee is growing mulberry leaves,
feeding them to silkworms and obtaining silk cocoons, income from the sale of silk cocoons is not an
agricultural income.
Income from a Nursery
Income from a nursery is always exempted from total income.

H.H. Maharaja Vibhuti Narain Singh v. State of Uttar Pradesh [1967] 65 ITR 364 (All.)

In this case, the Hon’ble Allahabad High Court held that income from a nursery is not an agricultural
income unless maintained by a farmer as an aid or necessary adjunct to the primary process of
agriculture, for example, paddy nursery, nursery of tomato plants. Here assessee used the nursery for
ornamental plants which can not be considered an adjunct to the primary agricultural process.

In the case of CIT v. Saundarya Nursery [2000] 241 ITR 530 (Mad.), the Madras High Court held that
nursing activities involve carrying out of several operations on land before the sapling were
transplanted in a particular pot and then put them in shades for further operation and growth.
Therefore, the income from the nursery will consider being an agricultural income.

Rent or Revenue from Land

Rent or Revenue is a kind of income derived from agricultural income by the landlord or the owner of
the land.

Rent can be in cash or in-kind. E.g.- if a person owns the land and gives it to another person on rent
for agricultural purposes @ Rs. 5,000, then this amount of income considered to be rent from land in
cash which is a part of agricultural income.

Rent or revenue derived from land should fulfill three essential conditions

Rent or revenue should be earned from land.- To receive rent or revenue, the most important point is
that it should be earned from land. Rent or revenue received from assets other than land will not be
considered as income derived from land.

Revenue which is received by the landlord should be from the direct and immediate source. If the land
is an indirect and secondary source then revenue will not be considered to be agricultural income. In
the support of the statement, there is a case-

Pratap Singh v. Province of Bihar [1949] 17 ITR 202 (pat.)

In this case, the Malikana allowance paid by the government under a legal obligation to an owner,
dispossessed of his land, is not revenue derived from land, as the immediate source of income is the
government’s legal obligation to pay compensation and not the land.

Land should be situated in India .- The Second essential condition is to be land should be situated in
India, otherwise, it will be considered to be income from other sources and will not include in
agricultural income. Land can either be in a rural or urban area. Some conditions are given under Sec.
2(1A)(c) of the Income Tax Act in regards to the Area which is considered to be land.

Land should be used for agricultural purposes.- The land should be used for Agricultural purposes.
We have discussed earlier the meaning of the term “Agricultural Purpose” with the help of case:

CIT v. Raja Benoy Kumar Suhas Roy [1957] 32 ITR 466, where SC laid down the principles of basic
operation and subsequent operation.

Mere connection with land will not be sufficient for Agricultural Purpose. There should be activities
in connection with agriculture. Activities like dairy farming, poultry farming, cheese and butter
making, etc. are not considered to be agricultural activities.

Illustrations –

A landowner receives rent in-kind from a tenant who grows wheat on that land, now the landowner
sells it in the market @ Rs. 20000. This income is derived from agricultural operation.

A landowner receives the rent of 1/3rd of whole wheat grown in his land. And he uses that wheat in
making biscuits and sells it in the market. Here, this activity is not considered to be an agricultural
operation because that income is business income.

Income derived from Agricultural produce and marketing processes

Any income derived by a cultivator or receiver of rent-in-kind from agriculture by the sale of
agricultural produce on which necessary operations( maybe or may not be needed)are carried on to
render the produce fit for consumption and taking it to market is called as agricultural income. Such
income is exempt from taxation. However in case of operations performed are not in nature as
mentioned above, income has to be separated so as to compute tax on non-agricultural income. The
operations mentioned above are called as agricultural or marketing operations.

There are two conditions which must be satisfied for marketing operation;

The agricultural process must be performed by a person employed by a cultivator or a receiver of rent-
in-kind.

That product should be fit to be taken to market.

There are some ordinary process employed to render the produce fit to be taken to market like-
thrashing, winnowing, cleaning, drying, crushing, boiling and decanting, etc. if the income derived
from these marketing process will be considered as agricultural income.

If the marketing process is performed on products that can be sold in the market in its raw form
without performing any operation which makes it fit for marketing, then that income will be
considered as partly agricultural and partly from a business.
Brihan Maharashtra Sugar Syndicate Ltd. v. CIT [1946] 14 ITR 611 (Bom.)

In this case, assessee carries the business in the manufacture and sale of sugar, and then he owns a
sugarcane farm and utilized this in the production of sugar. The court, in this case, held that the
process of converting sugarcane into sugar would not be agricultural process and the income derived
from this would not be agricultural income.

Income from Farm building

Income from farm building which is derived from Agricultural operation is exempted from tax. But to
satisfy that property is used for agricultural purposes there are some essential requirements that need
to be fulfilled. Those conditions are:

The building must be occupied by the cultivator or the receiver of rent-in-kind;

The land must be situated in India and used for agricultural purposes;

The building which is used for agricultural operations by the cultivator or the rent receiver must be as
a dwelling house, storehouse.

The land is assessed to land revenue or local rates or land is situated in rural areas.

Rural Areas for the above purpose are given under Sec.2(1A)(c)(ii) of the Act, any area not situated:

within the jurisdiction of municipality or cantonment board and where the population is not more than
ten thousand.

within 2km from the local limits of municipality or cantonment board, where the population is more
than 10000 but less than 1 lakh.

Within 6km from the local limits of municipality or cantonment board, where the population is more
than 1 lakh but less than 10 lakh.

Within 8km from the local limits of municipality or cantonment board, where the population is more
than 10 lakh.

The use of the building other than farming activity will not be exempted under Income Tax. E.g.- If an
owner gives that building on rent for residential purpose then income derived from that building will
not be exempted.

When Agricultural income consists of both Agricultural and non-

agricultural income
Income which is partially agricultural and partially non-agricultural is determined under rules 7, 7A,
7B and 8 of Income Tax Rules.
Rule 7.- under this rule, income which is partially agricultural income and partially income chargeable
under the head “profits and gains of business” then in determining chargeable income, the
government will determine the market value of agricultural produce which is raised by the assessee or
rent received by him and which has been utilised as a raw material in a business then only that amount
shall be deducted and no further deduction shall be made.

Rule 7A.- Income derived from the sale of centrifuged latex or Cenex or latex-based crepes (such as
pale latex crepe) or brown crepes (such as estate brown crepe, remilled crepe, smoked blanket crepe
or flat bark crepe) or technically specified block rubbers manufactured or processed from field latex
or coagulum obtained from rubber plants grown by the seller in India in the first instance, be
computed as if it were income derived from business. 35% of the income shall be deemed to be
income from business and shall be taxable.

No deduction shall be made from the income in respect of the amount of subsidy if allowance made in
respect of the cost of plating rubber plants in replacement of dead plants or become permanently
useless in an area already planted if such area has not been abandoned.

Rule 7B.- income derived from the sale of coffee grown and cured by the seller in India shall be
computed as income derived from the business. 25% of such income shall be taxable.

Income derived from the sale of coffee grown, cured, roasted and grounded by the seller in India, with
or without mixing chicory or other flavoring ingredients, shall be computed as income derived from
the business. 40% of such income shall be deemed to be taxable.

No deduction shall be made from the income in respect of the amount of subsidy if allowance made in
respect of the cost of plating rubber plants in replacement of dead plants or become permanently
useless in an area already planted if such area has not been abandoned.

Rule 8.- the income derived from the business of growing tea leaves and manufacturing tea shall be
computed as it was derived from business and 40% of the income shall be deemed to be taxable under
the Act.

CIT v. AFT Industries Ltd. [2004] 141 taxman 433 (cal.)

The cess levied under the West Bengal Rural Employment Production Act, 1976 and the West Bengal
Primary Education Act, 1973 is permissible as a deduction in computing the income from the
business. The cess does not fall under the prohibitory item of deduction.
CIT v. R.M. Chidambaram Pillai [1977] 106 ITR 292 (SC)

SC held that salary and interest received by a partner from a firm growing leaves and manufacturing
tea are taxable only to the extent of 40% and the balance of 60% income shall be treated as
agricultural income.

No deduction shall be made from the income in respect of the amount of subsidy if allowance made in
respect of the cost of planting bushes in replacement of dead bushes or become permanently useless in
an area already planted if such area has not been abandoned.

Computation of Tax on Non-Agricultural Income when Income has

Agricultural Income also
Agricultural income is exempted from taxation, but in some conditions, the Income Tax department
laid down a way for indirect tax from such incomes which we have discussed. This method called as
partial integration of agricultural income with non-agricultural income. According to this method,
higher rates of taxes imposed on non-agricultural income. There are some requirements for the
applicability of this method:

The taxpayer should be an individual, a Hindu undivided family, a body of an individual, an

association of person or an artificial juridical person.

The Non-agricultural income of the taxpayer exceeds the maximum amount non-chargeable to tax.
Non-agricultural income should exceed the amount of rs.2,50,000 for the individual below than 60
yrs. of age and rs.3,00,000 for the individual above than 60 yrs of age.

Agricultural income should be more than rs. 5000.

Calculation of Tax is done in the following manners

To calculate the total tax payable, there are four steps as follows:

Step 1: – Add agricultural income to non-agricultural income and calculate tax as if this is total
income.

Step 2: – Add agricultural income to the maximum amount non- chargeable to tax and calculate tax as
if this is total income.
Step 3: – Deduct tax computed in step 2 from tax computed in step 1. The amount so computed is the
actual tax payable.

Step 4: -Add surcharge, education cess, and secondary and higher education cess

CASE LAWS
Bacha F. Guzdar v. C.I.T., Bombay

The appellant, MrsBacha F. Guzdar, was, in the accounting year 1949-50, a shareholder in two Tea
companies, Patrakola Tea Company Ltd., and Bishnauth Tea Company Ltd., and received from the
aforesaid companies dividends aggregating to Rs 2750.

The two companies carried on the business of growing and manufacturing tea.

By Rule 24 of the Indian Income Tax Rules, 1922, it is provided that

Income derived from the sale of tea grown and manufactured by the seller in the taxable territories
shall be computed as if it were income derived from business and 40% of such income shall be
deemed to be income, profits and gains, liable to tax.

Therefore 40% of the income of the Tea companies was taxed as income from the manufacture and
sale of tea and 60% of such income was exempt from tax as agricultural income.

The contention of the Appellant,

The dividend income received by her in respect of the shares held by her in the said Tea companies is
to the extent of 60% agricultural income in her hands and therefore exempt from tax

The contention of the Revenue,

The dividend income is not agricultural income and therefore the whole of the income is liable to tax.
Supreme Court held that,

Agricultural income as defined in the Act is obviously intended to refer to the revenue received by
direct association with the land which is used for agricultural purposes and not by indirectly extending
it to cases where that revenue or part thereof changes hands either by way of distribution of dividends
or otherwise.

In fact and truth dividend is derived from the investment made in the shares of the company and the
foundation of it rests on the contractual relations between the company and the shareholder.

The dividend is not derived by a shareholder by his direct relationship with the land. Therefore
whosoever receives profit from the land directly is entitled to the exemption.

A shareholder does not receive profit directly from the land, though the company may be involved in
agricultural activities and is not entitled to the exemption.

CIT v. Raja BahadurKamakshya Narayan Singh dealt with the question of whether interest on arrears
of rent payable in respect of land used for agricultural purposes is agricultural income and therefore
exempt from Income Tax. It was held that it was neither rent nor revenue derived from land within the
meaning of Section 2(1A ) of the Income Tax Act.

Premier Construction Co. Ltd. v. CIT[xiv]dealt, with the nature of the commission of a managing
agent of the company, a part of whose income was agricultural income.

The assessee claimed exemption from tax on the ground that his remuneration at 10 percent of the
profits was calculated with reference to the income of the company part of which was agricultural
income. It was held that the assessee received no agricultural income as defined by the Act but that he
received a remuneration under a contract for personal service calculated on the number of profits
earned by the employer, payable not in specific, out of any item of such profits, but out of any moneys
of the employer available for the purpose, and that the remuneration, therefore, was not agricultural
income and was not exempt from tax.

“The principle to be derived from a consideration of the terms of the Income Tax Act is that where an
assessee receives income, not itself of a character to fall within the definition of agricultural income
contained in the Act, such income does not assume the character of agricultural income, by reason of
the source from which it is derived, or the method by which it is calculated.

In Maharaj Kumar Gopal Saran Narain Singh v. CIT

Annual payment for life to the assessee was not held to be agricultural income and therefore not
exempt from tax where the annuity arose out of a transfer made by the assessee of a portion of his
estate for discharging his debts and for obtaining an adequate income for his life. It was held that it
was not rent or revenue derived from land but money paid under a contract imposing personal liability
on the covenantor the discharge of which was secured by a charge on land.

In CIT v. Sir Kameshwar Singh

Profits received by usufructuary mortgagee were exempt from Income Tax on the ground that they
were agricultural income in the hands of the mortgagee.

It was held that such income in the hands of mortgagee amounts to “agricultural income” as the
usufructuary mortgagee had received profits directly from the land.

Therefore whosoever receives profit from the land directly is entitled to the exemption.

A shareholder does not receive profit directly from the land, though the company may be involved in
agricultural activities and is not entitled to exemption.

C.I.T. v. Benoy Kumar Sahas Roy

In this case, the court emphasized that certain basic operations should be carried out along with
subsequent operations. The Supreme Court observed that if the integrated activity of the agriculturist,
viz., agriculture, which includes the basic operations and the subsequent operations, is undertaken and
performed in regard to any land, that land can be said to have been used for agricultural purposes and
the income derived therefrom can be said to be agricultural income derived from the land by
agriculture.
In the very same judgment, the Supreme Court also considered the other activities in relation to the
land or having a connection with the land including breeding and rearing of live-stock, dairy-farming,
butter and cheese-making, poultry-farming, etc.

Nagi Reddi v. CIT

In this case, the assessee had shown certain income from film-shooting in his premises, which was
known as Vijaya Gardens, and he used to recover charges for the same. The assessee claimed that
those charges amounted to agricultural income as the said premises were used for agricultural
activities also. The assessing authority, however, treated it as business income. The assessee,
therefore, filed three separate appeals before the Tribunal.

The Tribunal held against the assessee on the basis of the earlier orders passed that the income earned
by the assessee by way of film-shooting charges did not amount to agricultural income. On a
reference, the High Court observed that the assessee used to grow agricultural produces like paddy
and derived income from fruit-yielding trees, etc. He earned income from rice, vegetables, fruits, etc.,
and, incidentally, he had also permitted film-producers to shoot their films in the said garden on
payment of hire charges.

It was the case of the assessee that had it not been for the vegetation, there would not have been any
occasion for the producers to shoot films in the garden and, it was because of that, that the income
earned from those shooting charges amounted to agricultural income. The High Court considered
whether the income earned by the assessee by permitting film producers to shoot their flms in his
garden could amount to agricultural income within the meaning of Section 2(1-A) of the Income-tax
Act, 1961.

The Court referred to the aforesaid decision of the Supreme Court in the case of Raja Benoy Kumar
Sahas Roy in which it was emphasized that certain basic operations should be carried out alongwith
subsequent operations. The Supreme Court observed that if the integrated activity of the agriculturist,
viz., agriculture, which includes the basic operations and the subsequent operations, is undertaken and
performed in regard to any land, that land can be said to have been used for agricultural purposes and
the income derived therefrom can be said to be agricultural income derived from the land by
agriculture. In the very same judgment, the Supreme Court also considered the other activities in
relation to the land or having a connection with the land including breeding and rearing of live-stock,
dairy-farming, butter and cheese-making, poultry-farming, etc.

The Supreme Court then went on to hold that the mere fact that an activity has some connection with
or is in some way dependent on land is not sufficient to bring it within the scope of the term
“agriculture”.
Applying the aforesaid principles, the Madras High Court held in Nagi Reddi’s case that income
earned by the assessee by way of shooting-hire charges by permitting film producers to shoot their
films in his garden was not agricultural income. The shooting of films is an activity which has no
nexus whatsoever with agricultural operations, or with the land, except that the shooting is done on
land which may be or has been agricultural land yielding some agricultural income. The nexus, as
claimed by the assessee, was non-existent, far-fetched and illusory.

To conclude, there is enough scope for taxing income from activities which are non-agricultural in
nature. In fact, it is well known that agriculturists themselves do not have taxable income, taking into
account the fact that when it is divided amongst family members who are involved in agricultural
operations, each one of them would have income within the exemption limit. However, there are
hundreds of thousands of middlemen like wholesalers, retailers, distributors, etc. who earn substantial
income from trading in agricultural produce as well as fruits, flowers, etc. Such income or profits are
fully taxable under the present law and, therefore, if concerted efforts are made by the Tax
Department to recover the tax from them, the need for widening the tax base to rope in agriculturists
and farmers, would be eliminated..

Conclusion
Agricultural income is exempt from income tax but State government by indirect ways. There are so
many methods and requirements for agricultural income as we have discussed. Any other process will
compute it as partly agricultural income and partly non-agricultural income.

REFERENCES:

[i]http://www.lawnotes.in/Section_2_of_Income-Tax_Act,_1961 as accessed on 25th Oct, 14.

[ii] ibid

[iii]http://finotax.com/income-tax/info/exempt-income as accessed on 25th Oct, 14.

[iv]http://yourfinancebook.com/definition-of-agricultural-income/as accessed on 25th Oct, 14.

[v]Dr. Raj, Kailash, ‘Taxation Laws”, Allahabad Law Agency, 9th edition, Faridabad (Haryana),
2007.Pg. no. 3

[vi]http://taxguru.in/income-tax/income-tax-treatment-taxability-of-agricultural-income.htmlas
accessed on 25th Oct, 14.

[vii]http://indiantaxguide.wordpress.com/2009/05/08/agricultural-income/as accessed on 25th Oct, 14.

[ix] T. Padma, Dr., “Principle of Law of Taxation”, ALT Publication, 10th Edition. Pg. no. 20.

[x] ibid

[xi]http://taxguru.in/income-tax/income-tax-treatment-taxability-of-agricultural-income.htmlas
accessed on 25th Oct, 14.

[xii]1955 AIR 740

[xiii]1971 AIR 794

[xiv][1948] 16 ITR 380 (PC)

[xv]http://taxadviceindiacom.blogspot.in/2012/10/case-laws-on-sec-2ia-agricultural-income.html as
accessed on 25th Oct, 14.

[xvi]3 I.T.R. 237

[xvii][1935] 2011 TPI 646

[xviii](1957) 32 ITR 466 (SC)

[xix] Supra Note 15.

[xx](1984) 147 ITR 337 (Mad)

[xxi]http://www.taxmanagementindia.com/tax-updates/?p=23441 as accessed on 25th Oct, 1