TMI Blog2014 (2) TMI 1197X X X X Extracts X X X X X X X X Extracts X X X X ..... d 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. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income Tax Act, 1961 without appreciating that the activity of development and marketing seeds is purely a commercial activity and does not fall under Agricultural activity? 2. Whether on the facts and circumstances of the case and in law, the Hon ble ITAT was correct in not appreciating the fact that the assessee s activity is composite in nature and production of basic seeds was with the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... treating the income generated from the sale of basic/foundation seeds as agricultural income. Therefore, the question is whether the income arising from out of the sale of seeds can be treated to be income otherwise than the agricultural income. No one can dispute that the seed is the product of agricultural activity and the seeds cannot be sold commercially, unless it is produced by agricultural ..... X X X X Extracts X X X X X X X X Extracts X X X X
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