Income from Cultivation of parent hybrid seed is non agricultural Income and taxable as business income

RELEVANT PARAGRAPH 52. From the nature of activity of the assessee as explained by the assessee, it is seen that the assessee in India is engaged in the business of the production and sale of various varieties of parent seed sold to its Joint Venture Company. During the year under consideration, the assessee has produced 1,81,319 kgs of seeds having opening stock of seed at 41,998 kgs, out of which 66,635 kgs of seeds (including seeds for own consumption of 1765 kgs) have been sold to its joint venture company leaving a closing stock of seeds at 1.15.995 kgs. For production of parent seed in l...