Mushroom cultivation treated as agricultural income where growth involves land-based operations and human labour.

Income from edible mushroom cultivation was treated as agricultural income because the activity was carried on from land through human skill and labour, involved basic operations on land, and the mushrooms remained attached to the soil during growth. On that reasoning, the sale proceeds were regarded as income within the statutory concept of agricultural income and therefore exempt under the Act. The Revenue's challenge to the exemption was rejected on the basis that mushroom cultivation satisfied the agricultural character test applied in the text.

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Issues: Whether income from cultivation of edible mushrooms is agricultural income and therefore exempt under the Act.

Analysis: The dispute turned on the character of mushroom cultivation. The first appellate authority and the Tribunal relied on the Special Bench view that edible mushrooms are raised from land through human skill and labour, that the activity involves basic operations on land, and that the product is attached to the soil during growth. On that reasoning, mushroom cultivation was treated as agricultural activity and the income arising from sale of mushrooms was regarded as income falling within the statutory concept of agricultural income.

Conclusion: The income from mushroom cultivation is agricultural income and the Revenue's challenge to its exemption fails.

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