THE COMMISSIONER OF INCOME-TAX,WEST BENGAL, CALCUTTA vs RAJA BENOY KUMAR SAHAS ROY

The Supreme Court ruled that income derived from the sale of forest trees can qualify as agricultural income under Section 2(1) of the Indian Income-tax Act, provided that significant human labor and skill are applied to the land. The Court held that the term 'agriculture' encompasses a range of activities, including planting and maintaining trees, which are integral to raising produce. The appeal was dismissed, affirming the High Court's decision that the income was indeed agricultural and exempt from taxation under Section 4(3)(viii).