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    <title>2011 (8) TMI 499 - ITAT CUTTACK</title>
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    <description>Income from sale of bonsai plants and nursery saplings grown on agricultural land was treated as agricultural income because the assessee had carried out essential cultivation operations, including planting, nurturing, watering, manuring, pruning and maintenance, until the plants became saleable. The distinction between bonsai plants and other saplings was considered immaterial where the underlying activity remained cultivation on land. The statutory definition of agricultural income under section 2(1A) of the Income-tax Act, 1961 was applied, and the income was also regarded as exempt under section 10(1). The later insertion of Explanation 3 to section 2(1A) was viewed as supporting the assessee&#039;s position.</description>
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      <link>https://www.taxtmi.com/caselaws?id=207335</link>
      <description>Income from sale of bonsai plants and nursery saplings grown on agricultural land was treated as agricultural income because the assessee had carried out essential cultivation operations, including planting, nurturing, watering, manuring, pruning and maintenance, until the plants became saleable. The distinction between bonsai plants and other saplings was considered immaterial where the underlying activity remained cultivation on land. The statutory definition of agricultural income under section 2(1A) of the Income-tax Act, 1961 was applied, and the income was also regarded as exempt under section 10(1). The later insertion of Explanation 3 to section 2(1A) was viewed as supporting the assessee&#039;s position.</description>
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