Agricultural income classification depends on land revenue assessment; kuthakapattom alone does not satisfy the statutory test.

Agricultural income from cardamom land is taxable as agricultural income under section 2(a) only if the land is assessed to land revenue in the State or is subject to a local rate assessed and collected by an officer of the Government. Kuthakapattom payable on Government land is not itself a land revenue assessment and does not satisfy that statutory condition. The assessment could not stand without a finding on those requirements, so the order was set aside and the matter remitted for determination of the statutory status of the land before treating the income as agricultural income.

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Issues: Whether the income derived from the cardamom land could be assessed as agricultural income under section 2(a) of the Agricultural Income-tax Act, depending on whether the land was assessed to land revenue or subjected to a local rate assessed and collected by an officer of the Government.

Analysis: Agricultural income under section 2(a) includes rent or revenue derived from land used for agricultural purposes only if the land is either assessed to land revenue in the State or subject to a local rate assessed and collected by officers of the State Government as such. Kuthakapattom payable on Government land is not tax assessed on the land and does not by itself satisfy this statutory requirement. The assessment could not therefore stand without a proper finding on the statutory conditions.

Conclusion: The assessment order was set aside and the matter was remitted to the Income-tax Officer to determine whether the land satisfied the statutory conditions before treating the income as agricultural income.

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