ITAT Rajkot: Hybrid Seed Company’s Income Held as Agricultural

Bombay Super Hybrid Seeds Limited Vs DCIT/ACIT (ITAT Rajkot) In this case, the ITAT Rajkot held that income earned by a company engaged in production of hybrid seeds on leased agricultural land qualifies as agricultural income and is exempt u/s 10(1), overturning the AO and CIT(A)’s view that it was business income. The Tribunal observed that the assessee had effective control over agricultural operations-it leased land, appointed coordinators, supervised farming activities, bore all risks, and incurred expenses for seeds, fertilizers, labour, and cultivation. Even though farmers physically ...