https://www.taxtmi.com/caselaws?id=10894 Rule 8 requires composite tea income to be computed first under the Income-tax Act and only then apportioned into agricultural and taxable components. On that footing, deductions relevant at the computation stage, including cess paid on green leaf, must be allowed in full before the 60:40 apportionment. Restricting the deduction only to the agricultural share after apportionment would undermine the statutory fiction and effectively tax part of the same amount twice in substance. The cess is therefore fully deductible in computing tea income before apportionment, and the Revenue's challenge fails. en-us Fri, 30 Jul 2004 00:00:00 +0530 Wed, 30 Dec 2015 16:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10894 Rule 8 requires composite tea income to be computed first under the Income-tax Act and only then apportioned into agricultural and taxable components. On that footing, deductions relevant at the computation stage, including cess paid on green leaf, must be allowed in full before the 60:40 apportionment. Restricting the deduction only to the agricultural share after apportionment would undermine the statutory fiction and effectively tax part of the same amount twice in substance. The cess is therefore fully deductible in computing tea income before apportionment, and the Revenue's challenge fails. Case-Laws Income Tax Fri, 30 Jul 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10894