The meaning of agriculture under section 2(1A) of the Income Tax Act is not defined in the act itself. But we can take guidance from decisions by various high courts. Here are excerpts of courts orders in which the Hon’ble High Court tried to explain the meaning of agriculture.
Meaning of agriculture defined by court
The phrase ‘agriculture’ used in section 2(1A) of the Income Tax Act came up before various high courts as detailed under :
1. Hon’ble Patna high court explained the meaning of ‘agriculture’ while delivering judgment in Smt. Manyam meenakshamma vs. CIT  63 ITR 534 (AP)/Syed rafiquar rahman vs. CIT as under :
Meaning : The word ‘agriculture’ means the performance of operations like tilling of the land, sowing of the seeds or planting in order to raise products of some utility. The nature of the products raised on the land is immaterial. The word ‘agricultural’ means ‘of or pertaining to agriculture; connected with husbandry or tillage of the ground’.
2. Hon’ble supreme court explained the meaning of ‘agriculture’ while delivering judgment in CIT v. Raja Benoy Kumar Sahas Roy  32 ITR 466 (SC) as under :
Meaning : Agriculture’ in its primary sense denotes the cultivation of the field and is restricted to cultivation of the land in the strict sense of the term, meaning thereby tilling of the land, sowing of the seeds, planting and similar operations on the land. These are basic operations and require the expenditure of human skill and labour upon the land itself.
Operations which the agriculturist has to resort to and which are absolutely necessary for the purpose of effectively raising produce from the land, e.G., Weeding, digging the soil around the growth, removal of undesirable undergrowth, and all operations which foster the growth and preservation of the same and save it not only from insects and pests
but also from depredation from outside, tending, pruning, cutting, harvesting and rendering the produce fit for the market, would all be agricultural operations when taken in conjunction with the basic operations. The human labour and skill spent in the performance of these subsequent operations cannot be said to have been spent on the land itself.
The mere performance of these subsequent operations on the products of the land, where such products have not been raised on the land by the performance of the basic operations, would not be enough to characterise them as agricultural operations.
Agriculture comprises within its scope the basic as well as the subsequent operations described above regardless of the nature of the products raised on the land. These products may be grain or vegetables or fruits.
3. Hon’ble Nagpur high court explained the meaning of ‘agriculture’ while delivering judgment in Beohar Singh Raghubir Singh v. CIT  16 ITR 433 (Nag.) as under :
Meaning : The essence of agriculture, even when it is extended to include ‘forestry’, is the application of human skill and labour. Without that it can be neither art nor a science.
4. Hon’ble Uttaranchal high court explained the meaning of ‘agriculture’ while delivering judgment in Cit v. Green gold tree farmers (p.) Ltd. 2007 Tax lr 609 (uttaranchal) as under :
Meaning : The terms ‘agriculture’ and ‘agricultural purposes’ not having been defined in the indian income-tax act, one necessarily has to fall back upon the general sense in which they have been understood in common parlance. ‘Agriculture’ in its root sense, means a gear, a field and cultivation of field which of course implies expenditure of human skill and labour upon land.
Section 2 of Income Tax Act
2. In this Act, unless the context otherwise requires,—
(1) “advance tax” means the advance tax payable in accordance with the provisions of Chapter XVII-C;
(1A) 1″agricultural income” means—
(a) any rent or revenue derived from land which is situated in India and is used for agricultural purposes;
(b) any income derived from such land by—
(i) agriculture; or
(ii) the performance by a cultivator or receiver of rent-in-kind of any process ordinarily employed by a cultivator or receiver of rent-in-kind to render the produce raised or received by him fit to be taken to market; or
(iii) the sale by a cultivator or receiver of rent-in-kind of the produce raised or received by him, in respect of which no process has been performed other than a process of the nature described in paragraph (ii) of this sub-clause;
(c) any income derived from any building owned and occupied by the receiver of the rent or revenue of any such land, or occupied by the cultivator or the receiver of rent-in-kind, of any land with respect to which, or the produce of which, any process mentioned in paragraphs (ii) and (iii) of sub-clause (b) is carried on :
(i) the building is on or in the immediate vicinity of the land, and is a building which the receiver of the rent or revenue or the cultivator, or the receiver of rent-in-kind, by reason of his connection with the land, requires as a dwelling house, or as a store-house, or other out-building, and
(ii) the land is either assessed to land revenue in India or is subject to a local rate assessed and collected by officers of the Government as such or where the land is not so assessed to land revenue or subject to a local rate, it is not situated—
(A) in any area which is comprised within the jurisdiction of a municipality (whether known as a municipality, municipal corporation, notified area committee, town area committee, town committee or by any other name) or a cantonment board and which has a population of not less than ten thousand; or
(B) in any area within the distance, measured aerially,—
(I) not being more than two kilometres, from the local limits of any municipality or cantonment board referred to in item (A) and which has a population of more than ten thousand but not exceeding one lakh; or
(II) not being more than six kilometres, from the local limits of any municipality or cantonment board referred to in item (A) and which has a population of more than one lakh but not exceeding ten lakh; or
(III) not being more than eight kilometres, from the local limits of any municipality or cantonment board referred to in item (A) and which has a population of more than ten lakh.
Explanation 1.—For the removal of doubts, it is hereby declared that revenue derived from land shall not include and shall be deemed never to have included any income arising from the transfer of any land referred to in item (a) or item (b) of sub-clause (iii) of clause (14) of this section.
Explanation 2.—For the removal of doubts, it is hereby declared that income derived from any building or land referred to in sub-clause (c) arising from the use of such building or land for any purpose (including letting for residential purpose or for the purpose of any business or profession) other than agriculture falling under sub-clause (a) or sub-clause (b) shall not be agricultural income.
Explanation 3.—For the purposes of this clause, any income derived from saplings or seedlings grown in a nursery shall be deemed to be agricultural income.
Explanation 4.—For the purposes of clause (ii) of the proviso to sub-clause (c), “population” means the population according to the last preceding census of which the relevant figures have been published before the first day of the previous year;
In this article, you can get guidance from high courts on the meaning of agriculture under section 2(1A) of the Income Tax Act.
Updated up to Finance Act 2021