Dairy farming income is not agricultural income when milk arises from milch cows maintained by the assessee.

Income from milk produced by milch cows maintained by the assessee was not treated as agricultural income because the expression "agriculture" was confined to its natural meaning and could not be extended to every activity connected with land. Rearing livestock and dairy farming were held to fall outside that meaning, so the income arising from such activity remained taxable rather than exempt under the Agricultural Income-tax Act, 1947. The Tribunal's view that the income was assessable was therefore affirmed.

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Issues: Whether income from milk derived from milch cows maintained by the assessee is agricultural income and therefore exempt from assessment under the Agricultural Income-tax Act, 1947.

Analysis: The question was held to be covered by the Supreme Court's exposition on the scope of the term "agriculture". The controlling principle applied was that the expression cannot be extended to every activity connected with land. Activities such as rearing livestock and dairy farming were treated as outside the natural meaning of agriculture, and income arising from such activity was therefore not agricultural income.

Conclusion: Income from dairy farming was not agricultural income, and the Tribunal's view that it was assessable was correct.

Ratio Decidendi: Dairy farming and income derived from milk production from maintained milch cows do not fall within the expression "agriculture" for purposes of agricultural income taxation.

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