Tea income computation must follow Central income-tax findings; State authorities cannot rewrite the assessment independently.

Tea income must be computed under the Central income-tax scheme, and State agricultural income-tax authorities cannot recalculate that income on a basis inconsistent with the Central computation. The State's deeming provision could not be used to enlarge taxable agricultural income or override the computation already made by Central officers. If the Central assessment is considered defective, the proper recourse is through the Central appellate or revisional machinery, not by a fresh State-level computation. The contrary assessments and appellate orders were therefore not legally sustainable and were liable to be set aside.

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Issues: Whether the State Agricultural Income-tax authorities could recompute tea income in a manner contrary to the computation already made by the Central Income-tax authorities, and consequently whether the impugned assessments and appellate orders were legally sustainable.

Analysis: The governing principle, as drawn from the earlier Supreme Court decisions relied upon, is that tea income has to be computed in accordance with the Central income-tax scheme and the State Legislature cannot enlarge the taxable agricultural income by permitting its officers to tinker with the computation already made under the Central enactment. If the State authorities consider that the Central assessment is defective, their remedy is to move the Central appellate or revisional machinery and not to substitute their own computation. The deeming provision in section 4(2) of the Agricultural Income-tax Act, 1991, therefore cannot be used to override or vary the computation made by the Central Officers.

Conclusion: The State authorities had no jurisdiction to recompute the agricultural income already computed by the Central Officers, and the assessments made on that contrary basis were invalid and liable to be set aside.

Ratio Decidendi: State agricultural income-tax authorities cannot recompute tea income contrary to the computation made under the Central income-tax law; any correction must be sought through the Central appellate or revisional process.

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