Agricultural income from casuarina plantations falls within the exemption because cultivation, not spontaneous forest growth, was decisive.

Income from casuarina plantations was treated as agricultural income because the plants were raised from land used for agricultural purposes through preparation of soil, planting, watering, pruning and sustained cultivation. The Court held that "agriculture" is not confined to food crops or to the narrow sense of tilling open fields, but extends to the raising of useful or valuable products from the soil by human labour and skill. Casuarina growth was therefore the result of cultivation rather than spontaneous forest growth, and the income was exempt under Section 4(3)(viii) of the Indian Income-tax Act, 1922.

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Issues: Whether income derived from casuarina plantations is agricultural income within the meaning of Section 2(1) of the Indian Income-tax Act, 1922, and exempt under Section 4(3)(viii).

Analysis: The expression "agricultural income" in the Act requires that the income be derived from land used for agricultural purposes. The Court held that the word "agriculture" is not confined to food crops or to the narrow sense of tilling open fields, but extends to the raising of useful or valuable products from the soil with the aid of human labour and skill. Casuarina plantations involve preparation of the soil, planting, watering, pruning, and cultivation over a period of years, and are therefore the result of human cultivation rather than spontaneous growth. The Court distinguished cases dealing with forest growth or special local enactments that adopted a narrower meaning of agriculture.

Conclusion: Income from casuarina plantations is agricultural income and is exempt from tax under Section 4(3)(viii) of the Indian Income-tax Act, 1922.

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