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    <title>2016 (10) TMI 165 - MADRAS HIGH COURT</title>
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    <description>Income derived from nursery operations on agricultural land, including the sale of plants, saplings and seeds, was treated as agricultural income because the factual findings showed cultivation and allied agricultural activity with human skill and labour. The Court relied on prior Division Bench authority recognising nursery produce as agricultural in nature where basic cultivation is involved, and upheld exemption under Section 10(1). Explanation 3 to Section 2(1A), inserted with effect from 01.04.2009, was held to be clarificatory rather than creating a new rule for later years only, so it did not defeat the assessee&#039;s claim for the earlier assessment year. The revenue&#039;s challenge failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=333145</link>
      <description>Income derived from nursery operations on agricultural land, including the sale of plants, saplings and seeds, was treated as agricultural income because the factual findings showed cultivation and allied agricultural activity with human skill and labour. The Court relied on prior Division Bench authority recognising nursery produce as agricultural in nature where basic cultivation is involved, and upheld exemption under Section 10(1). Explanation 3 to Section 2(1A), inserted with effect from 01.04.2009, was held to be clarificatory rather than creating a new rule for later years only, so it did not defeat the assessee&#039;s claim for the earlier assessment year. The revenue&#039;s challenge failed.</description>
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