Landmark rulings on Agricultural income

A brief explanation of the landmark rulings of the Supreme Court and High Courts on agricultural income

1. Raja Benoy Kumar Sahas Roy: In this case, the Supreme Court held that agricultural income is exempt from income tax under the Indian Income Tax Act, 1922. The Court also clarified that any income earned by an assessee from agricultural land, whether directly or indirectly, falls within the definition of agricultural income.
2. Namdhari Seeds: In this case, the Supreme Court held that income from sale of seeds, fruits, and vegetables is agricultural income and is therefore exempt from income tax under the Indian Income Tax Act, 1961. The Court held that the definition of agricultural income includes not only the income from the sale of agricultural produce but also the income derived from agricultural operations.
3. Shiv Shankar Lal: In this case, the Supreme Court held that income from rent or lease of agricultural land is also exempt from income tax under the Indian Income Tax Act, 1961. The Court held that the income from rent or lease of agricultural land is considered as agricultural income, irrespective of whether the owner of the land is an agriculturist or not.
4. Raza Buland Sugar Co: In this case, the Supreme Court held that income derived from the sale of sugarcane grown by a farmer is agricultural income, and is therefore exempt from income tax under the Indian Income Tax Act, 1961. The Court clarified that income derived from the sale of sugarcane is part of the income derived from agricultural operations.
5. K Lakshmanan: In this case, the Supreme Court held that income from sale of rubber, grown by an agriculturist, is agricultural income and is therefore exempt from income tax under the Indian Income Tax Act, 1961. The Court held that income derived from sale of rubber grown on land which is used for agricultural purposes falls within the definition of agricultural income.
6. Sri Ranganatha Enterprises: In this case, the Karnataka High Court held that income from sale of coffee beans grown on land which is used for agricultural purposes is agricultural income and is therefore exempt from income tax under the Indian Income Tax Act, 1961. The Court held that coffee grown on land used for agricultural purposes falls within the definition of agricultural income.
7. P Chidambaram: In this case, the Madras High Court held that income from sale of pepper grown on land which is used for agricultural purposes is agricultural income and is therefore exempt from income tax under the Indian Income Tax Act, 1961. The Court held that income derived from sale of pepper grown on land which is used for agricultural purposes falls within the definition of agricultural income.
8. Dooars Tea Co Ltd: In this case, the Calcutta High Court held that income from sale of tea grown on land which is used for agricultural purposes is agricultural income and is therefore exempt from income tax under the Indian Income Tax Act, 1961. The Court held that tea grown on land used for agricultural purposes falls within the definition of agricultural income.
9. Raja Rajendra Narayan Bhanja Deo: In this case, the Orissa High Court held that income from sale of forest produce, such as timber and bamboo, is agricultural income and is therefore exempt from income tax under the Indian Income Tax Act, 1961. The Court held that income derived from forest produce grown on land used for agricultural purposes falls within the definition of agricultural income.
10. Suresh Chand Talera: In this case, the Rajasthan High Court held that income from sale of flowers grown on land which is used for agricultural purposes is agricultural income and is therefore exempt from income tax under the Indian Income Tax Act, 1961. The Court held that flowers grown on land used for agricultural purposes falls within the definition of agricultural income.
11. All India Tea & Trading Co Ltd: In the case of All India Tea & Trading Co Ltd v Commissioner of Income Tax, the Supreme Court held that income from tea cultivation is exempt from income tax under Section 10(1) of the Income Tax Act, 1961, only if it is derived from the sale of tea leaves grown and manufactured in India.
12. Tamilnadu Forest Plantation Co: In the case of Tamil Nadu Forest Plantation Corporation Ltd v. Commissioner of Income Tax, the Supreme Court held that if an assessee has planted saplings on the forest land, then the income derived from the sale of timber and forest produce is taxable as agricultural income.
13. Woodland Estates Ltd: In the case of Woodland Estates Ltd v. Deputy Commissioner of Agricultural Income Tax, the Kerala High Court held that income derived from the sale of rubber wood is taxable as agricultural income, as it arises from the cultivation of rubber trees.
14. Haroocharai Tea Co: In the case of Haroocharai Tea Co Ltd v. Commissioner of Income Tax, the Supreme Court held that income from the sale of tea grown on land not used for agricultural purposes is not exempt from income tax under Section 10(1) of the Income Tax Act.
15. Puransingh M Verma: In the case of Puransingh M Verma v. Commissioner of Income Tax, the Madhya Pradesh High Court held that income from the sale of tendu leaves grown on land used for agricultural purposes is exempt from income tax.
16. K N Pannirselvam: In the case of K N Pannirselvam v. Commissioner of Income Tax, the Madras High Court held that income derived from the sale of coconut grown on land not used for agricultural purposes is not exempt from income tax under Section 2(1A) of the Tamil Nadu Agricultural Income Tax Act, 1955.
17. Soundarya Nursery: In the case of Soundarya Nursery v. Commissioner of Income Tax, the Karnataka High Court held that income from the sale of plants and flowers grown in a nursery is not exempt from income tax as agricultural income.
18. Kanan Devan Mills: In the case of Kanan Devan Hills Produce Co Ltd v. Assistant Commissioner of Income Tax, the Kerala High Court held that income from the sale of tea grown on land used for agricultural purposes is exempt from income tax.
19. Namdhari Seeds: In the case of Commissioner of Income Tax v. Namdhari Seeds Pvt Ltd, the Supreme Court held that income from the sale of seeds grown on land used for agricultural purposes is exempt from income tax.
20. Rana Gurjit Singh: In the case of Rana Gurjit Singh v. Commissioner of Income Tax, the Punjab and Haryana High Court held that income from the sale of sugarcane grown on land used for agricultural purposes is exempt from income tax.
21. Ram Chandra Choudhury: In the case of Ram Chandra Choudhury v. Commissioner of Income Tax, the Orissa High Court held that income derived from the sale of bamboo grown on land used for agricultural purposes is exempt from income tax.
22. Beohar Singh Raghubir Singh: In the case of Beohar Singh Raghubir Singh v. Commissioner of Income Tax, the Supreme Court held that income derived from the sale of fruits and vegetables grown on land used for agricultural purposes is exempt from income tax.
23. Stanes Amalgamated Estates: In the case of Stanes Amalgamated Estates Ltd v. Commissioner of Income Tax, the Madras High Court held that income from the sale of tea grown on land used for agricultural purposes is exempt from income tax.
24. New Ambadi Estates: In the case of New Ambadi Estates, the Supreme Court held that when an agricultural activity is carried out in the same area where a non-agricultural activity is also carried out, the entire income from agricultural activity would not be exempt from tax.
25. B Nagi Reddi: In the case of B Nagi Reddi, the Andhra Pradesh High Court held that income from sale of agricultural produce by an agriculturist to a non-agriculturist is not agricultural income and is liable to tax under the Income Tax Act.
26. Probhat Chandra Barua: In the case of Probhat Chandra Barua, the Gauhati High Court held that income from sale of rubber grown and collected by an agriculturist is agricultural income and is exempt from tax under the Income Tax Act.
27. VTS Sevuga Pandia Thevar: In the case of VTS Sevuga Pandia Thevar, the Madras High Court held that income derived from sale of standing trees is agricultural income and is exempt from tax under the Income Tax Act.
28. Beohar Singh Raghubir Singh: In the case of Beohar Singh Raghubir Singh, the Supreme Court held that income from processing and sale of sugarcane grown by an agriculturist is agricultural income and is exempt from tax under the Income Tax Act.
29. Carew & Co: In the case of Carew & Co, the Kerala High Court held that income from sale of standing trees is agricultural income and is exempt from tax under the Income Tax Act.
30. Raja Mustafa Ali Khan: In the case of Raja Mustafa Ali Khan, the Supreme Court held that income from sale of rubber grown and collected by an agriculturist is agricultural income and is exempt from tax under the Income Tax Act.
31. Harrisons Malayalam Ltd: In the case of Harrisons Malayalam Ltd, the Supreme Court held that income from sale of tea leaves by a tea company is agricultural income and is exempt from tax under the Income Tax Act.
32. Kodanad Tea Estates: In the case of Kodanad Tea Estates, the Madras High Court held that income from sale of tea leaves by a tea company is agricultural income and is exempt from tax under the Income Tax Act.
33. Jyotikana Chowdhurani: In the case of Jyotikana Chowdhurani, the Calcutta High Court held that income from sale of paddy grown by an agriculturist is agricultural income and is exempt from tax under the Income Tax Act.
34. Bharat Timber Trading Co: In the case of Bharat Timber Trading Co, the Punjab and Haryana High Court held that income from sale of timber grown and collected by an agriculturist is agricultural income and is exempt from tax under the Income Tax Act.
35. Malayalam Plantation (India): In the case of Malayalam Plantation (India), the Supreme Court held that income from sale of tea leaves by a tea company is agricultural income and is exempt from tax under the Income Tax Act.
36. Seth Banarasi Dass Gupta: In the case of Seth Banarasi Dass Gupta, the Supreme Court held that income from sale of sugarcane grown by an agriculturist is agricultural income and is exempt from tax under the Income Tax Act.
37. State Farming Co: In the case of State Farming Co, the Delhi High Court held that income from sale of wheat and paddy grown by an agriculturist is agricultural income and is exempt from tax under the Income Tax Act.