Slaughter-tapping income from purchased rubber trees was not agricultural income where no interest in the land was conveyed.

Income from slaughter-tapping of rubber trees is not agricultural income where the purchase documents transfer only the trees and no interest in the land. The Kerala HC distinguished cases in which the assessee owns both land and trees, noting that agricultural income treatment depends on the land-linked character of the operation. On the facts found, the purchasers acquired only the right to the trees, so the latex-derived income lacked the necessary connection with land and was not taxable as agricultural income.

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Issues: Whether income derived by purchasers of rubber trees from slaughter-tapping constituted agricultural income where the purchase documents showed that no interest in the land was conveyed.

Analysis: The documents of purchase were construed as transferring only the right to the trees and not any interest in the land. The Court distinguished cases where the assessee owned both the land and the trees, in which event income from latex obtained by slaughter-tapping would be agricultural income, from cases where the purchaser acquired only the trees. On the facts found, the assessees derived no interest in the land, and the income from slaughter-tapping could not be treated as agricultural income.

Conclusion: The income derived by the assessees from slaughter-tapping was not agricultural income, and the challenge to the single judge's decision failed.

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