Tax on Income from mushrooms grown in controlled conditions

DCIT Vs Inventaa Industries (P.) Ltd. (ITAT Hyderabad)

As basic operations are performed by expenditure of human skill and labour on land by the assessee, which results in the raising of the ‘product’ called Edible white button mushroom on the land and as this product has utility for consumption, trade and commerce, the income arising from the sale of this product is agricultural income and hence exempt u/s 10(1) of the Act.

FULL TEXT OF THE ITAT JUDGMENT

The Hon’ble President ITAT, constituted this Special Bench to decide the following question and appeals vide order dt.25-07-2017

“Merely because instead of horizontal use on soil, vertical space is used, does the growth of mushrooms stand apart from agricultural operations?”

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