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    <title>2025 (12) TMI 578 - ITAT DELHI</title>
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    <description>Income from hybrid seed cultivation was treated as business income, not agricultural income, because the assessee did not itself perform the essential basic agricultural operations; farmers carried out the cultivation, while the assessee only supervised, supplied parent seeds, processed the crop, and bought it at fixed rates. Interest on delayed receivables from associated enterprises was not automatically treated as a separate international transaction, because the receivable pattern, credit terms, and working-capital impact required case-specific examination, so the matter was remanded for fresh determination. Additions relating to capital expenditure, doubtful debts, CSR, and gratuity, bonus and compensated absence were also sent back for verification of the Dispute Resolution Panel directions.</description>
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      <description>Income from hybrid seed cultivation was treated as business income, not agricultural income, because the assessee did not itself perform the essential basic agricultural operations; farmers carried out the cultivation, while the assessee only supervised, supplied parent seeds, processed the crop, and bought it at fixed rates. Interest on delayed receivables from associated enterprises was not automatically treated as a separate international transaction, because the receivable pattern, credit terms, and working-capital impact required case-specific examination, so the matter was remanded for fresh determination. Additions relating to capital expenditure, doubtful debts, CSR, and gratuity, bonus and compensated absence were also sent back for verification of the Dispute Resolution Panel directions.</description>
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