Statutory context
**Income-tax Act, 2025** for tax year 2026-27 onwards. Agricultural income is defined in **section 2(5)** read with **Rule 270 of the Income-tax Rules, 2026**, and is not included in total income under **Schedule II, Serial No. 1 read with section 11(1)** — the old section 10 list having been reorganised into the Schedules. Earlier years remain on **section 2(1A)** and **section 10(1)** of the 1961 Act, and this page switches the whole set together with the year of the return. **CBDT instruction F. No. 173/49/2022-ITA-I dated 29 October 2025**, issued following a C&AG performance audit, directs assessing officers to independently verify documentary evidence under **land records** ("ownership & land type/ use- viz. Khasra-khatauni/7-12 extract/Mutation etc."), **input expenses** ("viz. tilling, irrigation, fertilizer/pesticides, electricity, labour, storage, transport etc") and **sales documents** ("viz. Mandi/Buyers receipts, bank statements etc."), not to allow the exemption for non-agricultural activity, and to apply the apportionment rules properly — while stating that its guidance is "only indicative & not exhaustive". On quantum, **Kalpana Devi v. ITO, Ward-3(1), Deoghar (ITAT Ranchi, ITA No. 72/Ran/2026, pronounced 10 September 2026)** accepted ₹8,91,570 on about twenty acres as "quite reasonable" in a reopened assessment, treating the previous year's acceptance on the same holding as a benchmark. Reassessment for tax year 2026-27 onwards runs on **section 279** (income escaping assessment), **section 280** (the notice) and **section 281** (the show-cause, the hearing, and a reasoned order with the prior approval of the Additional or Joint Commissioner); earlier years on **sections 147, 148 and 148A**. A disallowed claim carries penalty under **section 439 of the 2025 Act** (ex-**section 270A**) — **50%** of the tax on under-reported income, **200%** where it is characterised as misreported. Content checked 27 September 2026.