Sale proceeds from agricultural land are not agricultural income or revenue derived from land for tax exclusion purposes.

Consideration received on sale of agricultural land does not qualify as "agricultural income" under Section 2(1A) of the Income-tax Act because rent or revenue derived from land means income generated by the land itself, not proceeds from transfer of the land. Explanation 1 to Section 2(1A) reinforces that revenue derived from land excludes income arising on transfer of land falling within Section 2(14)(iii). On this plain reading, sale proceeds are not revenue derived from land, and the land sale destroys the income-generating asset rather than producing agricultural income. The sale consideration was therefore not excludable on that basis, and no question of law arose for interference.

---

---

Issues: Whether consideration received on sale of agricultural land could be treated as agricultural income or revenue derived from land so as to exclude it from book profit under the Minimum Alternate Tax provisions.

Analysis: The expression "agricultural income" under Section 2(1A) of the Income-tax Act, 1961 covers rent or revenue derived from land used for agricultural purposes. Explanation 1 to Section 2(1A) clarifies that revenue derived from land does not include income arising from transfer of land falling within Section 2(14)(iii). On a plain reading, sale proceeds from transfer of land are not revenue derived from land. In the absence of any specific statutory definition enlarging "revenue", the ordinary meaning of the term, read in the context of "rent", contemplates income generated by the land itself and not proceeds arising on its transfer. Sale of the land destroys the income-generating asset and therefore does not answer the description of agricultural income.

Conclusion: The sale consideration from agricultural land was not agricultural income or revenue derived from land, and no question of law arose for interference.

---