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<h1>Deemed taxable income from sale of home-grown tea: fixed portion treated as business income; replacement-planting allowance limited by subsidy exclusion.</h1> Income from sale of tea grown and manufactured by the seller in India is computed as business income, with forty per cent of such income deemed liable to tax. An allowance is allowed for the cost of replacing dead or permanently useless bushes in an area already planted that has not been abandoned, and in determining that cost any subsidy excluded from total income under clause (30) of section 10 must not be deducted.
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