Commission for personal services is not agricultural income merely because it is linked to agricultural profits.

Contractual commission paid to a managing agent for personal services did not become agricultural income merely because it was calculated as a percentage of the principal company's profits, including profits attributable to agricultural income. The character of the receipt depended on the nature of the income in the hands of the recipient, not on the source of the employer's profits or the formula used to measure the payment. Accordingly, the commission fell outside the statutory definition of agricultural income and was not exempt from income-tax.

---

---

Issues: Whether the managing agent's commission, calculated as a percentage of the principal company's profits and proportionate to agricultural income earned by the company, was agricultural income exempt from tax.

Analysis: The remuneration payable to the assessee was a contractual payment for personal services, with a minimum guaranteed amount and an additional percentage of profits if that amount was exceeded. The character of the receipt was determined by the nature of the income received by the assessee, not by the source from which the employer's profits were derived or the method used to calculate the commission. Income does not become agricultural income merely because it is measured by reference to agricultural profits of another person, unless the receipt itself falls within the statutory definition of agricultural income.

Conclusion: The commission was not agricultural income and was not exempt from income-tax.

---