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    <title>2022 (6) TMI 808 - CALCUTTA HIGH COURT</title>
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    <description>Nursery receipts from clonal plants, sugarcane and coconuts were treated as agricultural income because nursery activity involving land preparation, levelling, bed preparation, sowing and planting was regarded as agricultural operations; the Explanation to section 2(1A) did not change the result on the facts found. Deduction under section 80IA was upheld for captive power consumed within the assessee&#039;s own business units, since sale to outsiders is not required. Deduction under section 80IC was also allowed for products supplied only to another division of the same assessee, as the incentive provision was construed liberally and the statutory conditions were otherwise met. The provident fund and ESI issue was not examined on merits due to low tax effect.</description>
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      <description>Nursery receipts from clonal plants, sugarcane and coconuts were treated as agricultural income because nursery activity involving land preparation, levelling, bed preparation, sowing and planting was regarded as agricultural operations; the Explanation to section 2(1A) did not change the result on the facts found. Deduction under section 80IA was upheld for captive power consumed within the assessee&#039;s own business units, since sale to outsiders is not required. Deduction under section 80IC was also allowed for products supplied only to another division of the same assessee, as the incentive provision was construed liberally and the statutory conditions were otherwise met. The provident fund and ESI issue was not examined on merits due to low tax effect.</description>
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