SRISH CHANDRA SEN (DECEASED) AND OTHERS vs THE COMMISSIONER OF INCOME-TAX, WEST BENGAL

The Supreme Court held that the agricultural income derived from land, for which land revenue was redeemed by a lump-sum payment in 1865, is not liable to income tax under Section 2(1) of the Indian Income-tax Act, 1922. The Court reasoned that the redemption of land revenue effectively freed the land from any assessment, thus disqualifying the income as agricultural income. The appeal was dismissed, affirming the lower court's ruling that the income was taxable.