Section 10(1) of Income Tax Act, 1961—In the instant case, appeal is filed by revenue against order of CIT. The only issue raised in the present appeals is the treatment of activity of growing of hybrid seeds is whether agricultural activity or not.

Held that—  The CIT(A) while deciding the issue in the present case had in turn, relied on the decision of Pune Bench of Tribunal in ACIT Vs. Ajeet Seeds Ltd. (supra), which has been confirmed by the Hon’ble High Court. Consequently, we hold that growing of hybrid seeds in the case of assessee can never be held to be non-agricultural activity. Hence, the assessee is entitled to claim deduction under section 10(1) of the Act.[THE DY. COMMISSIONER OF INCOME TAX, CIRCLE 1 (2) , AND THE INCOME TAX OFFICER, WARD 1 (4) , PUNE VERSUS GENUINE SEEDS PVT. LTD.,][2019] 14 ITCD Online (1) [ITAT PUNE]