This compilation indexes 12 rulings from the Income Tax Appellate Tribunal (ITAT), various High Courts, and the Supreme Court of India in which Section 10(1) of the Income-tax Act, 1961, or a contextually analogous provision of the same section number in a state or central statute, was engaged. The cases span the period August 2019 to August 2026 and cover a range of forums — from ITAT benches at Bangalore, Nagpur, Hyderabad, and Mumbai to the High Courts of Allahabad, Himachal Pradesh, Madras, Rajasthan, Delhi, and Kerala, and the Supreme Court of India. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for locating relevant precedent.

Research index only. This page is a structured case-law reference compiled from the TaxNoticeAI legal corpus. Nothing on this page constitutes legal or tax advice. Readers must verify all rulings against the full original judgment and check for any subsequent stays, reversals, or appellate developments before relying on them in any professional context.

The statutory framework in one paragraph

Section 10(1) of the Income-tax Act, 1961 provides that agricultural income, as defined in Section 2(1A) of the Act, shall not be included in the total income of a person chargeable to tax. The exemption is absolute in the sense that qualifying agricultural income does not form part of the computation base for regular income-tax purposes, though it may be considered for rate purposes in certain circumstances involving non-agricultural income. The definition of "agricultural income" in Section 2(1A) encompasses rent or revenue derived from land situated in India and used for agricultural purposes, income derived from such land by agriculture itself, and income derived from any process ordinarily employed by a cultivator to render the produce fit for market. Note that Section 10(1) as referenced in non-income-tax statutes (such as various state land ceiling or forest land Acts) is a provision of those respective statutes and is distinct from Section 10(1) of the Income-tax Act, 1961; this compilation includes rulings from both contexts where Section 10(1) appears in the CASE_FACTS record, as retrieved from the source corpus.

The 12 rulings

1. Munna Lal vs State Of U.P. And 3 Others

Bench: Allahabad High Court
Date: 17 August 2026
Sections engaged: 10(1), 10(3), 10(5), 10(6), 6(1), 8(3), 8(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as Writ - C No. 42857 of 2023 before the Allahabad High Court, reserved on 09.07.2026 and delivered on 17.08.2026. Per the source preview, the petitioner sought quashing of an order dated 18.10.2023 passed by the Competent Authority, Urban Ceiling, Varanasi, which rejected the petitioner's representation for correction of revenue entries, and also sought directions to abate proceedings in Ceiling Case No. 486/2480/5523 and to expunge revenue entries in the name of the State in respect of land situated in Village Hasanpur, Pargana Shivpur, Varanasi, arising under the Urban Land (Ceiling and Regulation) Act, 1976.

2. Biri Singh vs State Of H.P. &Ors

Bench: Himachal Pradesh High Court
Date: 11 August 2026
Sections engaged: 10(1), 11
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as CWP No. 13111/2026 before the Himachal Pradesh High Court and decided on 11.08.2026. Per the source preview, the petitioner challenged an order dated 13.01.2025 by which the respondent authority declined to refer the petitioner's dispute for adjudication by the Labour Court-cum-Industrial Tribunal, primarily on the ground that the alleged dispute — concerning the petitioner's employment in the State Forest Department from July 2007 to March 2015 — was stale, having been raised by demand notice dated 21.08.2023 after a lapse of more than eight years from the alleged date of illegal termination without explanation for the delay.

3. Gurupadayya Swami, Kalaburagi vs Income Tax Officer, Ward-1 & Tps

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 6 July 2026
Sections engaged: 69A, 10(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 2127-2128/Bang/2025 for Assessment Years 2021-22 and 2022-23 before the ITAT Bangalore. Per the source preview, the assessee challenged the order of the CIT(A) confirming additions made by the Assessing Officer, involving two interconnected issues: (i) an addition of ₹18,65,000 on account of cash deposits in the bank account, and (ii) an addition of ₹21,45,900 representing agricultural income claimed as exempt under section 10(1) of the Act. The PAN on record is CTQPS1976N.

4. K.Abathsagayam vs Secretary To Government

Bench: Madras High Court
Date: 2 June 2026
Sections engaged: 9(2)(b), 10(1), 22
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as W.P. No. 14073 of 2004 before the Madras High Court, reserved on 30.04.2026 and delivered on 02.06.2026. Per the source preview, the petitioner filed a writ of certiorarified mandamus under Article 226 of the Constitution of India seeking to call for and quash the records of Special Revision Petition No. 5/2000 before the Tamil Nadu Land Reforms Special Appellate Tribunal, and consequentially to set aside proceedings in R.C.No.MRI/164/17/70/NNL/A6 dated 28.04.2004, in the context of Tamil Nadu land reforms proceedings.

5. Continental Engineering Corporation vs Jaipur Metro Rail Corporation

Bench: Rajasthan High Court - Jaipur
Date: 21 August 2025
Sections engaged: 34, 10(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as D.B. Special Appeal (Civil) No. 4/2022, arising out of S.B. Arbitration Application No. 117/2018, before the Rajasthan High Court at Jaipur, reserved on 28.07.2025 and pronounced on 21.08.2025. Per the source preview, the Special Appeal was preferred under Section 37(1)(c) of the Arbitration and Conciliation Act, 1996 by Continental Engineering Corporation Limited against Jaipur Metro Rail Corporation; the procedural context of the section 10(1) engagement as listed in the case record is noted without further substantive detail available from the source preview.

6. Maan Singh vs State Of H.P. &Ors

Bench: Himachal Pradesh High Court
Date: 16 June 2025
Sections engaged: 10(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was decided as a batch of connected writ petitions — CWP Nos. 9282, 9284, 9286, 9294, 9296, 9412, 9414 and 9416 of 2025 — before the Himachal Pradesh High Court on 16.06.2025. Per the source preview, the petitions involved common questions of law and fact and were taken up together with the consent of learned counsel for the parties; facts from CWP No. 9282 of 2025 (Maan Singh) were treated as the lead matter, and the petitioner felt aggrieved against an order passed by the respondent authority, with the substantive ground not further detailed in the available preview.

7. Lalita Dheeraj Junghare, Nagpur vs ITO, Ward-3(4), Nagpur

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 21 March 2025
Sections engaged: 10(1), 143(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA No. 360/Nag./2024 for Assessment Year 2020-21 before the ITAT Nagpur. Per the source preview, the assessee (PAN: ADLPJ2897A) held multiple agricultural land parcels in Hatla, Katol, Nagpur, and Kondhasaoli, Katol, Nagpur, with crops including oranges and nursery plants, totalling approximately 10.61 hectares (26.21 acres), and the appeal arises in the context of income from agricultural operations including orange cultivation, with the section 10(1) engagement indicating a claim of agricultural income exemption.

8. Asst. Commissioner Of Income Tax vs Nuziveedu Seeds Limited, R.R. Dist

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 31 May 2022
Sections engaged: 10(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeals were filed as ITA Nos. 1456, 1457, 1463 and 1464/HYD/2017 for Assessment Years 2012-13 and 2013-14 before the ITAT Hyderabad. Per the source preview, the appellant company was engaged in the business of research, production, and sale of agricultural seeds, and filed its return of income for AY 2012-13 admitting a total income of ₹17,78,44,464/- under normal provisions and book profit under section 115JB at ₹14,74,06,124/-; the case was selected for scrutiny and notices were issued, with section 10(1) engaged in the context of the agricultural seeds business. PAN on record is AACCN7214Q.

9. State Of Tamil Nadu vs M.S. Viswanathan

Bench: Supreme Court of India
Date: 20 September 2021
Sections engaged: 10(1), 11(1), 11(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was heard as Civil Appeal No. 5881 of 2010 (with Civil Appeal No. 5885 of 2010) before the Supreme Court of India. Per the source preview, the State of Tamil Nadu and officials of the Department of Urban Land Ceiling challenged (i) an order of the Division Bench of the Madras High Court dismissing an intra-court appeal, and (ii) a subsequent order of the Division Bench refusing to condone the delay in seeking review of the original order, arising in the context of the Tamil Nadu Urban Land (Ceiling and Regulation) Act, 1978, which came into force partly on 28.03.1978 and was deemed to have come into force partly on 03.08.1976.

10. Mr. Yashovardhan Birla, Mumbai vs CIT (A)-51, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 3 September 2021
Sections engaged: 10(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was heard as SA No. 61/Mum/2021 (arising out of BMA No. 01/Mum/2021) before the ITAT Mumbai for Assessment Year 2016-17. Per the source preview, the proceedings involved the appellant (PAN: AAJPB2505N) and the source preview discloses a list of bank accounts held in Switzerland across multiple institutions and account names; the full substantive ground and the precise engagement of section 10(1) are not further detailed in the available preview beyond the procedural record.

11. Del Small Ice Cream Manufacturers vs Union Of India & Anr

Bench: Delhi High Court
Date: 9 February 2021
Sections engaged: 10(2)(e), 10(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Per the source preview, this petition (W.P.(C) 5252/2019) was filed before the Delhi High Court by a manufacturers' welfare association challenging the decision dated 18th June, 2017 of the Goods and Services Tax Council to exclude ice cream from the benefits of the Composition Scheme, invoking Section 10(2)(e) of the Central Goods & Services Tax Act, 2017. The petition contended that the said exclusion was in violation of the spirit of Articles 14 and 19 of the Constitution of India and against the principles of natural justice. Readers should verify the precise regime context before citing this ruling in an income-tax research note, as the substantive dispute is rooted in the GST Composition Scheme.

12. Government Of Kerala vs Jacob Thomas Arikupuram

Bench: Kerala High Court
Date: 20 August 2019
Sections engaged: 10(1), 3(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter was heard as MFA.(Forest) No. 88 of 2016 before the Kerala High Court, decided on 20.08.2019, against the order dated 22-06-2015 in OA No. 8/2011 of the Tribunal for E.F.L. Cases (I Additional District Court), Kozhikode. Per the source preview, the appeal was filed by the Government of Kerala and its forest officials challenging the tribunal's order in proceedings concerning ecologically fragile lands, with the respondents being private landowners in Alappuzha District; the substantive engagement of section 10(1) as listed in the case record is noted, with further detail not available from the source preview.

Patterns across these 12 rulings

Agricultural income exemption as a recurring income-tax flashpoint. Among the income-tax specific rulings (cases 3, 7, and 8), section 10(1) of the Income-tax Act, 1961 is engaged consistently in the context of agricultural income claims — whether involving cash deposits alongside agricultural income claims (case 3), orange and nursery cultivation income (case 7), or income from an agricultural seeds business (case 8). Across these three ITAT rulings, the assessee's claim of exemption under section 10(1) was the central or a significant co-issue before the tribunal.
State land ceiling and regulation statutes share section numbering with the Income-tax Act. Several cases in this compilation — including cases 1, 4, 9, and 12 — arise under state Urban Land Ceiling Acts, land reforms Acts, or ecologically fragile land legislation, where "Section 10(1)" refers to a provision of that state or central statute, not the Income-tax Act, 1961. Researchers using section-number searches should verify the statute under which any given "Section 10(1)" is invoked before drawing interpretive parallels.
Multi-petitioner batch matters. Case 6 (Maan Singh, Himachal Pradesh High Court) illustrates a pattern of common-question batch proceedings, where multiple writ petitions involving the same or similar grievances against the State are consolidated and decided together using the lead petitioner's facts. This procedural pattern affects how the ruling binds or applies to each individual petitioner.
Broad forum spread. The 12 rulings in this index span four ITATs (Bangalore, Nagpur, Hyderabad, Mumbai), six High Courts (Allahabad, Himachal Pradesh, Madras, Rajasthan, Delhi, Kerala), and the Supreme Court, reflecting that questions touching on Section 10(1) — whether under the Income-tax Act or other statutes — arise across the entire judicial hierarchy and geography of India.
Outcome data gaps. All 12 rulings in this compilation carry the outcome designation "Outcome not specified in source," indicating that the structured corpus did not capture a dispositive outcome field for these matters. Researchers should access the full judgment text from the source portal to ascertain the final order in each case.

How to use this compilation

This compilation is a structured entry point for legal and tax research, not a substitute for reading the full judgment. Before citing any ruling listed here, researchers should obtain the complete text of the order from the relevant court portal (indiankanoon.org, the official High Court website, or the ITAT e-filing portal), verify the exact holding, and confirm whether the ruling has been stayed, appealed, reversed, or distinguished in subsequent proceedings. Section 10(1) rulings under state land ceiling, land reforms, or forest land statutes are distinct from rulings under the Income-tax Act, 1961, and the two bodies of law should not be conflated even where the section number is identical.

For income-tax specific research, readers should additionally cross-reference any ITAT ruling against any High Court or Supreme Court order that may have been passed in the same matter on further appeal. Where a ruling touches on agricultural income under section 10(1) of the Income-tax Act, 1961, practitioners should also check contemporaneous CBDT circulars and instructions on the definition of "agricultural income" under Section 2(1A), as administrative guidance may be relevant to the interpretive question before the assessing authority or tribunal.

This index will be updated as additional rulings are added to the TaxNoticeAI corpus. The date of compilation is noted in the article frontmatter; rulings pronounced after that date will not be reflected here unless the article is revised.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 10(1) Agricultural Income Exemption: 12 Rulings Across ITAT, HC & SC (2019–2026)