HC held that income derived by the assessee from sale of tissue cultured plants constitutes "agricultural income" under Section 2(1A) of the Act and is exempt under Section 10(1). The Bench found that mother plants are cultivated on land owned or leased by the assessee through basic agricultural operations such as tilling, planting, nurturing and harvesting, and that the subsequent tissue culture in laboratories is merely an advanced propagation technique intrinsically linked to such cultivation. Use of modern scientific methods, including tissue culture, does not alter the agricultural character of the activity or convert it into a commercial/business operation. The substantial question of law was answered in favour of the assessee, and the Revenue's challenge was rejected.
HC held that income derived by the assessee from sale of tissue cultured plants constitutes "agricultural income" under Section 2(1A) of the Act and is exempt under Section 10(1). The Bench found that mother plants are cultivated on land owned or leased by the assessee through basic agricultural operations such as tilling, planting, nurturing and harvesting, and that the subsequent tissue culture in laboratories is merely an advanced propagation technique intrinsically linked to such cultivation. Use of modern scientific methods, including tissue culture, does not alter the agricultural character of the activity or convert it into a commercial/business operation. The substantial question of law was answered in favour of the assessee, and the Revenue's challenge was rejected.
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