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    <title>2025 (11) TMI 1145 - ITAT BANGALORE</title>
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    <description>Income from tissue culture activity in a nursery was treated as agricultural income because the process formed part of integrated nursery operations carried on with agricultural land and connected cultivation activities. The Tribunal noted that the tissue culture step was preceded and followed by agricultural operations, and the income arose from the overall growing and sale of plants, seedlings and flowers. Explanation 3 to Section 2(1A) deems income from saplings or seedlings grown in a nursery to be agricultural income, so the related exemption under Section 10(1) applied. The tissue culture component could not be segregated and taxed separately as business income merely because one stage did not itself involve direct cultivation on land.</description>
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    <pubDate>Fri, 17 Oct 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=781677</link>
      <description>Income from tissue culture activity in a nursery was treated as agricultural income because the process formed part of integrated nursery operations carried on with agricultural land and connected cultivation activities. The Tribunal noted that the tissue culture step was preceded and followed by agricultural operations, and the income arose from the overall growing and sale of plants, seedlings and flowers. Explanation 3 to Section 2(1A) deems income from saplings or seedlings grown in a nursery to be agricultural income, so the related exemption under Section 10(1) applied. The tissue culture component could not be segregated and taxed separately as business income merely because one stage did not itself involve direct cultivation on land.</description>
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