Held that soil is a part of land and, therefore, part of earth. The only part of the land that is cultivable is the soil, which is the top layer of land. When soil is placed on trays, it did not cease to be land and operations carried out on that soil would be agricultural activity. Whether such soil was attached to the land or placed in containers above the land made no difference. Soil which is placed on a vertical space above the land in trays is also land. That the word product could not be restricted to plants, fruits, vegetables or such botanical life only. The only condition was that the product should be raised on the land by performing some basic operations. Mushroom is a product raised on land or soil by performing certain basic operation. It drew nourishment from the soil and was grown by human skill and labour. The product had utility for consumption, trade and commerce and, hence, would qualify as an agricultural product the sale of which gave rise to agricultural income.(AY.2020-21)