The Rambam writes the following in Hilchos Bikurim 2:9:
"What grows in a pot, even though the pot has a hole, and what grows in a boat - one does not bring for Bikurim at all, as the verse says 'b'Artzam'."
Essentially he is saying that bicurim is not brought from something that grew in a pot, even if it had holes inside of it.
Normally I though we say a pot with holes is "yonek" (derives from the ground.) And therefore we look at it as if it's part of the ground (in regards to trumos, maaseros, shvi'is.) Why not also here? Is it because of the limud of "b'artzem" as the Rambam points out.
Is perhaps my understanding of the halacha of a pot with holes in it not true or not according to all opinions (perhaps the Rambam.) When does the din of a "pot with holes" apply that we look at it as part of the ground and why not in this case?
Yehoshua, Yerushalayim, Eretz Yisrael
I believe that generally you are correct, as is the implication of the Rambam that without a specific Pasuk this would be included. If you would like to see the laws of a "pot with holes," I would suggest learning the Mishnah l'Melech on this Rambam who delves into what exactly is a pot with holes, which pots are considered to have holes without having holes, etc.
All the best,
Yaakov Montrose