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    <title>1920 (5) TMI 1 - CALCUTTA HIGH COURT</title>
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    <description>Profits from tea operations were treated as a composite receipt because cultivation and plucking were agricultural, while withering, rolling, drying, fermentation, sorting and packing were manufacturing stages. The agricultural element fell within the exemption, but the non-agricultural element remained taxable. Where income is derived partly from agriculture and partly from business or manufacture, the assessment can stand only to the extent of the taxable portion; a taxing statute cannot be extended beyond its clear words by practice or equitable construction. The assessment therefore had to be restricted to the portion not qualifying as agricultural income.</description>
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    <pubDate>Mon, 31 May 1920 00:00:00 +0530</pubDate>
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      <title>1920 (5) TMI 1 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=277385</link>
      <description>Profits from tea operations were treated as a composite receipt because cultivation and plucking were agricultural, while withering, rolling, drying, fermentation, sorting and packing were manufacturing stages. The agricultural element fell within the exemption, but the non-agricultural element remained taxable. Where income is derived partly from agriculture and partly from business or manufacture, the assessment can stand only to the extent of the taxable portion; a taxing statute cannot be extended beyond its clear words by practice or equitable construction. The assessment therefore had to be restricted to the portion not qualifying as agricultural income.</description>
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      <pubDate>Mon, 31 May 1920 00:00:00 +0530</pubDate>
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