https://www.taxtmi.com/caselaws?id=2994 Deduction under section 80HHC could be claimed only against the taxable 40% of composite tea income after apportionment under Rule 8(1), because the rule treats sale proceeds of tea grown and manufactured by the assessee as composite income with 60% deemed agricultural income outside the normal computation provisions. The legal fiction in Rule 8(1) was confined to splitting tea income and could not be extended to apply a Chapter VI-A deduction to the non-taxable agricultural component before apportionment. Section 80HHC, being a deduction from gross total income, therefore operated only on the income remaining after the statutory split. en-us Wed, 12 Dec 2007 00:00:00 +0530 Tue, 03 Feb 2015 15:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=2994 Deduction under section 80HHC could be claimed only against the taxable 40% of composite tea income after apportionment under Rule 8(1), because the rule treats sale proceeds of tea grown and manufactured by the assessee as composite income with 60% deemed agricultural income outside the normal computation provisions. The legal fiction in Rule 8(1) was confined to splitting tea income and could not be extended to apply a Chapter VI-A deduction to the non-taxable agricultural component before apportionment. Section 80HHC, being a deduction from gross total income, therefore operated only on the income remaining after the statutory split. Case-Laws Income Tax Wed, 12 Dec 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=2994