When a farmer processes their own agricultural produce in their own business (e.g., sugarcane → sugar, groundnuts → oil), income must be split using Rule 270. The farming portion — Fair Market Value (FMV) of raw produce minus cultivation cost — remains exempt agricultural income. The processing profit — sale price minus FMV minus manufacturing cost — is taxable business income.
Farmers or agro-processors who grow produce and also manufacture it into a finished product in their own unit (sugarcane → sugar, groundnuts → oil, cotton → yarn, etc.).
Scenario
Mr. Amar grows sugarcane. 40% of his crop (worth ₹12L at market) is sold raw to traders. 60% is sent to his own sugar factory where cane (FMV ₹25L) is converted into sugar (sold for ₹30L). Cultivation costs: ₹6L for direct-sale portion, ₹15L for factory portion. Manufacturing expenses: ₹1.5L.
Calculation
── 40% DIRECT SALE (raw) ────────────────────── Sale proceeds: ₹12,00,000 Less cultivation cost: – ₹6,00,000 Agri income (exempt): ₹6,00,000 ✓ ── 60% FACTORY PROCESSING ──────────────────── Step A — Farming portion (Rule 270): FMV of raw sugarcane: ₹25,00,000 Less cultivation cost: – ₹15,00,000 Agri income (exempt): ₹10,00,000 ✓ Step B — Manufacturing portion: Sugar sale proceeds: ₹30,00,000 Less FMV of cane: – ₹25,00,000 Less mfg expenses: – ₹1,50,000 Business income (taxable): ₹3,50,000 ────────────────────────────────────────────── Total Agri Income (exempt): ₹16,00,000 Total Business Income (taxable): ₹3,50,000
Result
Mr. Amar's ₹16L farming income is completely exempt. Only his ₹3.5L manufacturing profit is taxable as business income. Without Rule 270, the entire ₹42L receipts could be taxed — Rule 270 protects the genuine agricultural value at each stage.
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Section references are based on the Income Tax Act 2025 (Tax Year 2026-27). Examples are illustrative — verify with a Chartered Accountant before filing.