Sec. 2(1)

Sec. 2(1), Sec. 2(1A), Section 2, Section 80HHC

S.C : 40 apportionment under r.8(1) or from 40 per cent profits on sales taxable as business income.Rule 8(1) of the said rule provides that 40 per cent of the composite income from sale of tea, grown and manufactured, arrived at on making of the apportionment “shall be deemed to be income liable to tax”. Assessees exported tea in the accounting year. They were entitled to deduction under s. 80HHC

Supreme Court Of India CIT vs. Willamson Financial Services & Ors. Section 2(1A), 10(1), 80HHC, IT Rule 8, Art. 245,

Sec. 2(1)

Karnataka H.C : the assessee had a right by way of profit- a-pendere having interest in the land in the light of the decision of Supreme Court in Smt. Shanbha Bai vs. State of Bombay AIR 1958 SC 532 and the fact that the applicant itself did not have to carry basic agricultural operations personally and also that the extraction of latex is an agricultural operation and the income derived was not agricultural income

High Court Of Karnataka Bharat Timber Trading Co. vs. CIT Section 2(1)(a) Asst. Year 1982-83 R. Gururajan & N. Ananda,

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