Judgment :- CHITRA VENKATARAMAN, J. 1. The assessee is on appeal as against the order of the Income Tax Appellate Tribunal, relating to the assessment year 2001-02, raising the following substantial question of law: "Whether on the facts and circumstances of the case, the Appellate Tribunal was right in law in holding that the income from the sales of coconut shell, coconut leaves, coconut coir and wood and cattle are not agricultural in nature?" 2. The assessee claims that the income earned on the sale of coconut coir, coconut leaves, coconut shell, wood and cattle are all agricultural income, exempted under the provisions of the Income Tax Act. The Assessing Officer rejected the said plea and pointed out that the assessee owned 70 acres of agricultural lands and in 35 acres, he had coconut trees. The report of the Inspector shows that the total number of coconut trees in the 35 acres of land were 1750, out of which, yielding trees were 1600 and approximately 1,75,000 nuts were expected from these trees per year. The Inspector estimated the agricultural income from these trees at Rs.8.25 lakhs per annum. The assessee, however, returned an agricultural income of Rs.19.55 lakhs. The assessee contended that he converted coconut into copra and by selling copra, he would get a better price. Considering this aspect, the agricultural income was taken as Rs.10 lakhs and the balance amount was treated as income from other sources. 3. In considering the claim of the assessee, the Officer pointed out that in respect of the balance 35 acres, the assessee had grown sugarcane, grains and plaintains and the claim of the assessee in respect of this extent was accepted. However, as far as the income earned by way of sales of coconut coir, coconut leaves, coconut shell, wood and cattle were concerned, there had been no evidence let in to prove that the receipt of income could, in any way, be related to or having any direct proximity with agriculture, to treat the income as agricultural income. Thus, the Officer rejected the claim of the assessee. As far as the sale of cattle was concerned, the claim of the assessee that it was a business income, was also rejected. 4. Thus, the Officer rejected the claim of the assessee. As far as the sale of cattle was concerned, the claim of the assessee that it was a business income, was also rejected. 4. Aggrieved by this, the assessee went on appeal before the Commissioner of Income Tax (Appeals), who pointed out that the Assessing Officer had not pointed out any specific defect for making estimation of Rs.5 lakhs as not agricultural income. Thus, the appeal of the assessee was allowed. 5. Aggrieved by this, the Revenue went on appeal before the Income Tax Appellate Tribunal. Upsetting the order of the Commissioner of Income Tax (Appeals), the Tribunal pointed out that the income earned on the sale of coconut coir, coconut shell, coconut leaves, wood and cattle could not be exempted as agricultural income and following the decision of this Court reported in [1998] 232 ITR 443 (Commissioner of Income Tax Vs. Stanes Amalgamated Estates Ltd. (Mad), the Tribunal upheld the order of assessment. 6. We do not find there exists any justifiable ground to accept the plea of the assessee to hold that the income earned from the sale of coconut coir, coconut leaves, coconut shells, wood and cattle could be treated as agricultural income. In the decision reported in [1957] 32 ITR 466 (Commissioner of Income Tax Vs. Raja Kumar Sahas Roy), the Apex Court pointed out that the mere performance of an operation on the products of the land would not be enough to characterise them as agricultural operation. In order to give them the character of an agricultural operation, the subsequent operations must necessarily be in conjunction with and in continuation of the basic operations which are the effective cause of the products being raised from the land. Thus the subsequent operations divorced from the basic operations could not constitute, by themselves, agricultural operations. Hence, the income derived from the integrated activity which constitutes agriculture alone could be said to have the characteristics of an agricultural income, derived from the land by way of agriculture. 7. As far as the present case is concerned, it is no doubt true that the assessee had 35 acres of land which had a fairly substantial number of coconut trees. 7. As far as the present case is concerned, it is no doubt true that the assessee had 35 acres of land which had a fairly substantial number of coconut trees. Yet, there are hardly any material to show the kind of operation done therein and even if any such operation were undertaken, in the absence of any integrated activity shown that the products viz. Coconut shell, coconut leaves and coconut coir would fall under the extended meaning of agricultural products, we do not find any justifiable ground to agree with the plea of the assessee. The submission that the performance of the subsequent operation on the products have its origin on the agricultural products, cannot, however, justify the claim of the assessee that the income earned on the sale of coconut coir, coconut shell and coconut leaves could be treated as agricultural income. As far as wood and cattle are concerned, we do not find any justifiable ground to treat them as agricultural income to qualify for exemption. In the result, the Tax Case Appeal stands dismissed. No costs.