Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
Rule 7B, not the general composite-income rule, governs income from coffee grown and processed by the seller; for self-grown coffee, 40% is taxable as business income and 60% retains agricultural character. The ITAT accepted that the assessee also purchased coffee from other planters and processed and sold it, but Rule 7B did not extend to that purchased coffee in the same manner. The matter was therefore remanded to the Assessing Officer for fresh computation after segregating income from the assessee's own coffee estate from income arising on purchased coffee, with agricultural exemption available only to the self-grown produce.
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