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    <title>2003 (9) TMI 783 - ITAT DELHI</title>
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    <description>Rule of consistency did not bind the Revenue because earlier years had only been processed under section 143(1) without a conscious adjudication on the agricultural character of the income. Nursery income from plants raised through integrated cultivation activities, including soil preparation, sowing, propagation, grafting, watering and manuring, was treated as agricultural income under section 2(1A) and exempt under section 10. However, profit from plants purchased for resale, where no basic agricultural operations were carried out, was held to remain taxable and outside the exemption.</description>
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    <pubDate>Thu, 18 Sep 2003 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=176280</link>
      <description>Rule of consistency did not bind the Revenue because earlier years had only been processed under section 143(1) without a conscious adjudication on the agricultural character of the income. Nursery income from plants raised through integrated cultivation activities, including soil preparation, sowing, propagation, grafting, watering and manuring, was treated as agricultural income under section 2(1A) and exempt under section 10. However, profit from plants purchased for resale, where no basic agricultural operations were carried out, was held to remain taxable and outside the exemption.</description>
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      <pubDate>Thu, 18 Sep 2003 00:00:00 +0530</pubDate>
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