THE COMMISSIONER OF INCOME-TAX,BIHAR AND ORISSA vs SRI RAMAKRISHNA DEO

The Supreme Court held that income derived from the sale of trees in a forest does not qualify as agricultural income under Section 2(1) of the Indian Income-tax Act, 1922, and is thus not exempt from taxation under Section 4(3)(viii). The Court emphasized that the burden of proof lies with the claimant to establish entitlement to the exemption, and the findings of the Appellate Tribunal regarding the nature of the trees were binding on the High Court under Section 66(1). Consequently, the income was deemed taxable as it was derived from trees that were not planted by the respondent.