Supreme Court · 2007 INSC 1275 · Decided 12 December 2007
Commissioner of Income Tax v. Willamson Financial Services and ORS.
- Court
- Supreme Court of India
- Citation
- 2007 INSC 1275 · [2007] 13 S.C.R. 376
- Case number
- CIVIL APPEAL No. 3803-3808/2005
- Decided
- 12 December 2007
- Bench
- S.H. KAPADIA, B. SUDERSHAN REDDY (2-judge bench)
- Outcome
- Disposed off
- Case type
- Civil
- Acts & sections cited
- Constitution Article 246(1), 366(1); Income Tax Act
Headnote
-+ Income Tax Act, 1961: c s. 80HHC-Composite income from sale of tea, grown and manufactured-Export of tea-Deduction under s. 80HHC-Held: Allowable after 60: 40 apportionment of income under Rule 8(1)-The said rule segregates agricultural income which is ~xempted income, from business income 60 : 40 is applied-Therefore chargeability and computability is confined to only 40% of the income from tea which is taxable under Income Tax Act, 1961-In view of this, assessee cannot claim s.80HHC(3)(a) deduction against the entire tea composite income-Moreover Deductions under Chapter VL4 are
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