Earned income relief requires direct personal exertion for other-source income, not income produced through managers or staff.

Earned income relief under section 2(6AA) was confined to income directly and immediately derived from the assessee's personal exertion. The provision was construed according to its plain meaning, distinguishing business income, where carrying on the business could suffice, from income under other sources, where direct personal effort was required without an intermediate agency. On the facts, the assessee's forest and other-source income was produced with the assistance of managers and staff, so the necessary immediacy of personal exertion was absent. Relief was therefore denied and the claim failed.

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Issues: Whether income from other sources was entitled to earned income relief under section 2(6AA) of the Indian Income-tax Act only if it was immediately derived from the assessee's personal exertion.

Analysis: The definition of earned income in section 2(6AA) was construed according to the plain and ordinary meaning of its words. The scheme of the provision showed a distinction between business income, where the assessee's carrying on of the business was sufficient, and income under the head other sources, where the taxable income had to be immediately derived from the assessee's personal exertion. The expressions immediately and personal exertion were treated as requiring direct personal effort without the intervention of an intermediate agency. On the facts, the assessee had not shown direct personal control or immediate personal exertion in producing the income from forests and other sources, and the use of managers or staff negatived the necessary immediacy.

Conclusion: The assessee was not entitled to earned income relief on the income from other sources.

Final Conclusion: The question referred was answered against the assessee, and the claim for earned income relief on the disputed income failed.

Ratio Decidendi: For income chargeable under the head other sources, earned income relief is available only where the income is brought into existence by the assessee's direct and immediate personal exertion, without reliance on an intermediate agency.

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