The assessee produced high yielding hybrid seeds. It purchased seeds and then produced hybrid seeds in the net houses and marketed the seeds. The AO held that the activity carried on by assessee was not agricultural activity and treated the receipts as income of assessee and denied the exemption.  The CIT(A) deleted the addition.  Dismissing the appeal of the revenue the Tribunal held that growing of hybrid seeds could never be held to be non-agricultural activity. Accordingly entitle for exemption.  (AY.  2012-13, 2013-14).