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HC held that income derived from production and sale of hybrid seeds qualified as agricultural income within s.10(1) because the appellant, although not directly tilling land, exercised supervision, technical guidance, contractual control and bore risk and expense of cultivation carried out by farmers to produce parent and hybrid seeds. The Court concluded the operations constituted agricultural activity carried out through contractors, establishing a direct nexus with land. Accordingly, the HC allowed the appellant's appeal, treating the receipts as exempt agricultural income and reversing the characterization that disallowed exemption, while recognising the legitimacy of production-by-contract and the appellant's effective control over cultivation.
HC held that income derived from production and sale of hybrid seeds qualified as agricultural income within s.10(1) because the appellant, although not directly tilling land, exercised supervision, technical guidance, contractual control and bore risk and expense of cultivation carried out by farmers to produce parent and hybrid seeds. The Court concluded the operations constituted agricultural activity carried out through contractors, establishing a direct nexus with land. Accordingly, the HC allowed the appellant's appeal, treating the receipts as exempt agricultural income and reversing the characterization that disallowed exemption, while recognising the legitimacy of production-by-contract and the appellant's effective control over cultivation.
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