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of HC held that income from controlled environment cultivation of white 'Button Mushrooms' does not qualify as 'Agricultural Income' under Section 2(1A) of the Income Tax Act. The court determined that the income fails to meet the statutory criteria for agricultural income, specifically noting that the mushroom production in a factory setting does not satisfy the requisite conditions of land usage, agricultural purpose, or processing by a farmer. Consequently, the appellate court ruled in favor of the Income Tax Department, rejecting the assessee's claim for agricultural income tax exemption under Section 10(1) of the Act.
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