The assessee declared loss from sale of agricultural land. The assessee also claimed deduction on agricultural income. The AO held that the sale of agricultural land and its exclusion from the minimum alternate tax provision had resulted in its exclusion from the calculation of the book profits of the assessee under section 115JB(2)(ii) which was wrong. The CIT (A) held that the income of the assessee that arose from the transfer of agricultural land fell within the terms of items (a) and (b) of section 2(14)(iii) and section 10(1) and fell outside the ambit of the revenue derived from land and therefore, outside the ambit of “agricultural income”, that therefore such income was liable to capital gains tax under S. 45 of the Act. The Tribunal held that the findings of the Assessing Officer were correct. It held that the consideration received on sale of agricultural land did not constitute agricultural income and upheld the disallowances made by the AO. On appeal, dismissing the appeal, that the Tribunal was right in restoring the view of the Assessing Officer that the sale of agricultural land and its exclusion from the minimum alternate tax provisions had resulted in its exclusion from the calculation of the book profits of the assessee which was wrong. Textually, “revenue” derived from land is not deemed to have been included in any income arising from transfer of land. The Explanation to section 2(1A) was introduced by the Finance Act, 1989, with retrospective effect from April 1, 1989. The provision, per se, itself is clinching. In the absence of any specific definition as to what constitutes “revenue” under the Act, the normal meaning attributable (having regard to the rule of ejusdem generis, with respect to the expression “rent” used) would necessarily mean any form of income derived from the asset, i. e., the land which in turn pre-supposes its existence in the hands of the assessee. The other interpretation given by the assessee that even sale constituted “revenue” could not be accepted because the transaction of sale had resulted in destruction of a revenue or generating asset. No question of law arose.(AY. 2014-15)