- (1.) These three income-tax appeals involve common questions of law and fact and hence are being disposed of by a common judgment.
(2.) Heard learned counsel for the parties.
(3.) The assessee owns a plant nursery where he grows ornamental and decorative plants which he sells and derives income therefrom. The assessee alleges that this is agricultural income as he performs agricultural operation. He has relied on the Supreme Court decision in CIT v. Raja Benoy Kumar Sahas Roy [1957] 32 ITR 466.;