Appeals from the judgment and order dated December 9, 1964, of the Madras High Court in Tax Case No.
The assessee, who is the respondent is a limited companypany carrying on business of tea planting.
698 to 700 of 1963.
It owns several tea estates in the States of Tamil Nadu, Kerala and Assam.
He deducted from it the.expenditure allowed by the Central Income tax Officer and recalculated it from the Madras portion on the basis of acreage.
In respect of agricultural income from tea grown and manufactured by the seller in the State of Madras, the portion of the income worked out under the Indian Income tax Act and left unassessed as being agricultural shall be assessed under the Act after allowing such deductions under the Act and the rules made thereunder Provided that the companyputation made by the Indian Income tax Officer shall ordinarily be accepted by the Agricultural Income tax Officer who may, for his satisfaction under sections 16 and 16 of the Act, obtain further details from the assessee or from the Indian Income tax Officer but shall number without the previous sanction of the Assistant Commissioner of Agricultural.
CIVIL APPELLATE JURISDICTION Civil Appeals Nos.
That led to a profit from the Madras portion.
One of the tea estates owned by the assessee is called Chittavurai Tea Estate and companyprises 1043 acres of tea plantations.
Its head office is in Munnar in the State of Kerala.
The Judgment of the Court was delivered by Grover, J. These appeals from a companymon order of the High Court of Madras are by certificate.
As pointed out by the High Court the companyputation by the Central, Income tax Officer showed a loss for the entire Chittavurai Estate.
11751178 of 1970.
146 of 1963 and Writ Petitions Nos.
tax Act treating the Chittavurai Estate as one unit, the Agricultural Income tax Officer took the valuation of the produce from the Madras portion as the gross receipt.
C. Chagla, B. D. Datta, J. B. Dadachanji, 0.
Out of this an area of 1006.60 acres is situate in Kerala and the remaining 36.40 acres, in Tamil Nadu.
T. Desai and A. V. Rangam, for the appellant in both the appeals .
C. Mathur, Ravinder Narain and Jay Jesepp, for the respondent in all the appeals .
It is number necessary to go into details of how the companyputation was made by the Agricultural Income tax Officer.
