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2014 (2) TMI 1197 - HC - Income TaxEligibility of deduction under Section 10(1) - whether activity of development and marketing seeds is purely a commercial activity and does not fall under Agricultural activity - ITAT allowed claim - Held that:- We are unable to accept the far-fetched idea that artificial production of seeds can be sold or used for commercial purpose. May be a few hybrid seeds could be produced by artificial method in a laboratory. The seeds so produced with non-agricultural activity again will have to be sown in the agriculture field to have a larger quantity for sale in the market. Accordingly, we hold that the seed is a product of agricultural activity. Therefore, the sale of the same cannot be brought under the provisions of the Income Tax Act. We, therefore, upheld the decision of the learned Tribunal in this matter. - Decided in favour of assesse.
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