Agricultural income treatment upheld for floriculture and tissue culture where cultivation on land remained the essential activity.

Income derived from floriculture and tissue culture was treated as agricultural income because the Tribunal found the operations involved basic cultivation on land, with greenhouse and nurturing processes not altering the agricultural character of the produce. It followed its earlier decisions on identical facts in the assessee's own prior years and held that the existence of a greenhouse or tissue culture setup did not convert the activity into non-agricultural business activity. The income was therefore covered by the definition of agricultural income and remained eligible for exclusion under section 10(1).

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Issues: Whether the income derived from floriculture and tissue culture was agricultural income exempt under section 10(1) of the Income-tax Act, 1961.

Analysis: The Tribunal followed its earlier decisions in the assessee's own cases for prior assessment years on identical facts. It held that the operations involved basic cultivation on land, with subsequent greenhouse and nurturing processes not altering the agricultural character of the produce. The existence of a greenhouse or tissue culture setup did not, by itself, convert the activity into a non-agricultural business activity.

Conclusion: The income from floriculture and tissue culture was agricultural income under section 2(1A)(b)(i) and was eligible for exclusion under section 10(1); the Revenue's challenge failed.

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