Court held that agricultural income is granted an exemption under section 10. Sub-clause (2) of the first Explanation to section 115JB, provides a downward adjustment of the profits as revealed from the books of account, to that income, to which any of the provisions of section 10 , 10A , 10B , 11 or 12 applies. If any portion of the profits as reflected in the books of account relates to agricultural income, then there is a clear exemption provided under section 10. In view of the exemption under section 10, any revenue from agricultural land would have to be reduced from the profits in computing the minimum alternate tax under section 115JB. Explanation 1 to section 2(1A) however specifically excludes any income derived from transfer of land, referred to in items (a) and (b) of section 2(14)(iii) from the definition of “revenue derived from land”. This exclusion brought in by way of abundant caution, as is evident from the words employed cannot lead to a corollary being drawn of inclusion of sale of agricultural land as agricultural income or as revenue derived from land. Agricultural income as defined under section2(1A), inter alia, takes within its ambit “any rent or revenue derived from land, which is situated in India and is used for agricultural purposes”. The words “revenue derived from land” employed in the sub-clause, would only take within their ambit the periodic payments or revenue derived, when the owner of the property is not divested of the title and the land continues to be used for agricultural purposes. When a sale of agricultural land is made, the purchaser is not obliged to carry on agricultural land is made, the purchaser is not obliged to carry on agricultural operations, nor can the consideration received on such sale of agricultural land deemed to be agricultural income. The consideration received on sale of agricultural land in a rural area, not coming under section 2(14)(iii)(a) and (b) would not be income or revenue derived from land. It has to be added to the profit and loss account and would be reflected in the book profits, for assessment under section 115JB. There is no statutory provision enabling a downward adjustment of the sum from the book profits in the computation as provided in section 115JB. Provision for gratuity would be an ascertained liability and hence, would be capable of being deducted from computation of the minimum alternate tax under section 115JB. (AY. 2006 -07)