Foundation Seed Income Held Agricultural – ITAT Grants Section 10(1) Exemption

Daftari agro Biotech Pvt. Ltd. Vs Ward 9(3)(1) (ITAT Mumbai) The ITAT Mumbai allowed the assessee’s claim of agricultural income exemption under Section 10(1), holding that production and sale of foundation seeds constitutes agricultural activity. The Assessing Officer had denied exemption of about ₹70.99 lakhs, treating the activity as commercial/business income, citing the assessee’s earlier status as an R&D company and its linkage with hybrid seed production. The CIT(A) upheld this view. However, the Tribunal observed that: The assessee carried out basic agricultural operations s...