A composite lease of tea estates was held to be an agricultural...

A composite lease of tea estates was held to be an agricultural arrangement, not taxable renting of immovable property, because it was directed to plantation operations such as cultivation, harvesting and processing of green tea leaves, with consideration linked to agricultural output. The Tribunal held that land, labour quarters, staff facilities and machinery integral to plantation activity could not be artificially split into separate taxable services, and the demands for manpower supply and supply of tangible goods also failed because there was no independent consideration, possession, or effective control by the recipient. The impugned orders were set aside, and limitation, interest and penalties did not survive.