Sir John Beaumont in the above case observed : " In their Lordships ' view the principle to be derived from a consideration of the terms of the Income tax Act and the authorities referred to is that where an assessee receives income, not itself of a character to fall within the definition of agricultural income contained in the, Act, such income does not assume the character of agricultural income by reason of the source from which it is derived, or the method by which it is calculated. " In the third case, viz., Maharajkumar Gopal Saran Narain Singh vs Commissioner of Income tax, Bihar and Orissa(1), an annual payment for life to the assessee was not held to be agricultural income and therefore not exempt from tax where the annuity arose out of a transfer made by the assessee of a portion of his estate for discharging his debts and for obtaining an adequate income for his life it being held that it was not rent or revenue derived from land but.