The Constitution Bench in CIT v. Raja Benoy Kumar Sahas Roy , (1957) 32 ITR 466 (SC), laid down the foundational test: 'agriculture' for income-tax purposes requires basic operations on the land — tilling, sowing, planting. Mere…
10(1)
ITA 1961 · Section 10(1)
Agricultural Income
ITA 1961Up to AY 2025-26
Section 10(1) — Agricultural Income
The Constitution Bench in CIT v. Raja Benoy Kumar Sahas Roy, (1957) 32 ITR 466 (SC), laid down the foundational test: 'agriculture' for income-tax purposes requires basic operations on the land — tilling, sowing, planting. Mere 'subsequent operations' (preservation, harvesting) without basic operations is NOT agriculture.
HELD: The basic operations are those by which the cultivator brings the land under his use for the purpose of raising any crop or product. Mere subsequent operations like watering, weeding, harvesting cannot, by themselves, transform a non-agricultural product into agricultural produce. (per Raja Benoy Kumar Sahas Roy ¶ 16).