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    <title>2001 (5) TMI 170 - ITAT PANAJI</title>
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    <description>Receipts from allowing a factory to draw water from a pond in agricultural land were held to be revenue in nature because the arrangement was a continuing commercial agreement with recurring annual consideration, and no capital asset was transferred or sold. The pond remained with the assessee, so the payments arose from exploitation of the water resource rather than from capital disposition. The receipts were also not agricultural income merely because the pond was situated on agricultural land. They were therefore taxable as revenue income and not exempt agricultural income or capital receipts.</description>
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      <title>2001 (5) TMI 170 - ITAT PANAJI</title>
      <link>https://www.taxtmi.com/caselaws?id=70955</link>
      <description>Receipts from allowing a factory to draw water from a pond in agricultural land were held to be revenue in nature because the arrangement was a continuing commercial agreement with recurring annual consideration, and no capital asset was transferred or sold. The pond remained with the assessee, so the payments arose from exploitation of the water resource rather than from capital disposition. The receipts were also not agricultural income merely because the pond was situated on agricultural land. They were therefore taxable as revenue income and not exempt agricultural income or capital receipts.</description>
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