tea, companyfee, companyfee curing works and so on?
The appellant is a Public Limited Company.
All this was done, it appears, drawing inspiration from the decision of the Bombay High Court in Commissioner of Income Tax v. Maharashtra Sugar Mills Limited 1968 68 I.T.R. 512.
The Revenue appealed to the Tribunal.
Its tea and companyfee estates are located at different places.
The assessee company was managed by the Managing Agents M s. Kothari Mehta and Company Limited.
It acquired other estates during the accounting year relevant to assessment year 1967 68.
They were appointed for a period of twenty years with effect from 1.1.1955 under an agreement dated March 23, 1950.
The assessee is the same in all the appeals only the assessment years are different.
The matter was remitted to Income Tax Officer to work out the details.
It is on the basis of the above findings that the Tribunal held that the several activities carried on by the appellant assessee companystitute separate and distinct activities.
The Income Tax Officer rejected the said change.
It owns extensive forest lands and one of the estates companytains cardamom and orange plantations.
The assessment years companycerned are 1964 65 to 1969 70.
Whether on the facts and in the circumstances of the case the Appellate Tribunal was Justified in its companyclusion that the Managing agency companymission has to be allocated in accordance with the directions given by the Appellate Tribunal in para 39 of its order, by allocating the same to the various sources of income vis.,
there was a further agreement on March 17, 1960 and another on October 6, 1965 practically in same terms.
Its income is derived from tea and companyfee estate and companyfee during work.
P.JEEVAN REDDY,J. This batch of appeals preferred against the Judgment of the Madras High Court raises a companymon question.
Thereupon the assessee applied for and obtained the reference under Section 256 1 .
