Profarm Seed India P. Ltd. v. ITO (2023)101 ITR 120/ 198 ITD 113 (Hyd.)(Trib.)

S. 10(1) : Agricultural income-Engaged in producing foundation seeds and selling to various seed companies-Engaged labours and supervisors-Operation not of contract farming-Exemption justified.

Held, that the assessee took the agricultural lands on lease and conducted normal agricultural operations to produce a hybrid variety of foundation seeds in order to sell them in the open market to the seed industries, and in that pursuit engaged labour and supervisors. The assessee had produced voluminous record to show the engagement of labour and the payment of salaries to the supervisors and the agreements with the landowners. Merely because the assessee took the land on lease for conducting its research operations to produce foundation seeds of hybrid varieties, such a lease could not ipso facto make the operations of the assessee contract farming. Therefore, there was no illegality or irregularity in the conclusions reached by the Commissioner (Appeals). (AY. 2014-15)