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    <title>2024 (11) TMI 564 - ITAT MUMBAI</title>
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    <description>Income from cultivation and sale of white button mushrooms was treated as agricultural income exempt under section 10(1) of the Income-tax Act, 1961. The Tribunal applied the principle that mushroom cultivation on prepared soil or composite substrate remains land-based agricultural activity, even where carried on in trays, vertical beds, or controlled conditions, because the crop is raised from soil by human skill and labour and derives nourishment from the soil. On that basis, the receipts were not assessable as business income, and the alternative claim for cultivation expenditure and depreciation was not separately examined.</description>
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      <description>Income from cultivation and sale of white button mushrooms was treated as agricultural income exempt under section 10(1) of the Income-tax Act, 1961. The Tribunal applied the principle that mushroom cultivation on prepared soil or composite substrate remains land-based agricultural activity, even where carried on in trays, vertical beds, or controlled conditions, because the crop is raised from soil by human skill and labour and derives nourishment from the soil. On that basis, the receipts were not assessable as business income, and the alternative claim for cultivation expenditure and depreciation was not separately examined.</description>
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