COMMISSIONER OF INCOME TAX Vs. WOODLAND ESTATES LIMITED

JUDGEMENT

(1.) THIS is a reference by the Income -tax Appellate Tribunal, Madras Bench, under section 66(1) of the Indian Income -tax Act, 1922. The question referred i :

(2.) SECTION 2(1) of the Act defines the expression 'agricultural income' and section 4(3)(viii) of the Act provides that 'agricultural income' shall not be included in the total income of an assessee. The relevant portion of the definition reads as follow :

(3.) THE extract from the definition of 'agricultural income' given above makes it quite clear that two conditions have to be satisfied in order to come within its ambit. They ar :