Q.State, with reasons, whether the following is agricultural income: royalty received by a landowner for allowing stone-quarrying operations on his agricultural land.

Extracting a mineral resource from land is a fundamentally different activity from growing a crop on it, whatever the land's normal use.

Section 2(1A)'s definition of agricultural income turns on income arising from AGRICULTURE — cultivation, growing crops, and the marketing-preparation or sale of such produce. Quarrying stone from land is the extraction of a mineral resource; it involves no cultivation, sowing, or growing of anything, and is entirely unconnected to the land's agricultural character, even though the land may otherwise be used for agriculture. The royalty the landowner receives is compensation for permitting this extraction activity, not revenue derived from an agricultural use of the land, so it falls outside Section 2( …

Assuming that because the LAND is classified as agricultural land, every receipt connected with that land is automatically agricultural income — the exemption depends on the NATURE OF THE ACTIVITY (genu …