The Commissioner of Income Tax vs Linga Reddi

Murray Coutts Trotter, Kt., C.J.—In my opinion this case is unarguable. The assessee was a licensee of the Krishnapatam Salt Factory in

the Nellore District. From the manufacture of salt on the land of which he was the lessee he made a profit of some Rs. 7,000 which has been

assessed to Income Tax. He now contends that this is agricultural income, that it is revenue derived from the land which is used for agricultural

purposes and therefore not taxable. To my mind it would be a gross misnomer to hold that ""agricultural purposes"" could be held to cover the

process of flooding'' the land occupied by letting in the sea water and then extracting the sodium chloride from it by eliminating the other chemical

constituents. In my opinion the assessment was right and must be confirmed. The answer to the specific question referred is in the negative. The

assessee will pay the costs of this reference. Counsel''s fee Rs. 250.

Wallace, J.

I agree.

Beasley, J.

I agree.