Harvested crops before estate purchase were not agricultural income in the purchaser's hands under agricultural income-tax law.

Crops already harvested before the estate purchase did not constitute agricultural income of the purchaser under the Coorg Agricultural Income-tax Act, 1951. The income had accrued to the vendor who raised and removed the produce before the transfer, so it was not derived by the assessee from its own agricultural operations, any ordinary process employed by a cultivator to make produce fit for market, or the sale of produce raised or received by it. The amount realised from those harvested crops was therefore not taxable as agricultural income in the assessee's hands.

---

---

Issues: Whether the value of crops already harvested before the purchase of the estate constituted agricultural income of the assessee under the Coorg Agricultural Income-tax Act, 1951.

Analysis: Income from harvested crops had accrued to the vendor who raised and removed the produce before the assessee acquired the estate. Such income was not derived by the assessee from agricultural operations carried on by it, nor from any process ordinarily employed by a cultivator to make produce fit for market, nor from sale of produce raised or received by the assessee. The assessee's receipt from purchasing harvested crops in that condition was, therefore, not agricultural income.

Conclusion: The amount realised from crops already harvested before the date of purchase was not agricultural income of the assessee and was not taxable in its hands.

---