The term ‘agriculture’ and ‘agricultural purposes’ not having been defined in the Indian Income-tax Act, one necessarily has to fall back upon the general sense in which they have been understood it in common parlance. ‘Agriculture’ in its root sense, means agar, a field, and cultura cultivation, cultivation of field which of course implies expenditure of human skill and labour upon land - CIT v. Green Gold Tree Farmers (P.) Ltd. [2007] Tax LR 609 (Uttaranchal).
The word ‘agriculture’ means the performance of operations like tilling of the land, sowing of the seeds or planting in order to raise products of some utility. The nature of the products raised on the land is immaterial. The word ‘agricultural’ means ‘of or pertaining to agriculture; connected with husbandry or tillage of the ground’ - Smt. Manyam Meenakshamma v. CWT [1967] 63 ITR 534 (AP)/Syed Rafiqur Rahman v. CWT [1970] 75 ITR 318 (Pat.).
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