https://www.taxtmi.com/caselaws?id=35156 Charges under a ginning and pressing agreement were treated as composite receipts, because the arrangement included storage facilities in godowns as well as labour and allied operations. A flat attribution of 50% of the charges as rental income was held unsustainable, since the true income element attributable to storage had to be determined by proportional factual allocation rather than a blanket percentage. The court noted that a remand for fresh allocation was impracticable after a long delay, but rejected the mechanical departmental method and indicated that future assessment years should follow proportional apportionment of the composite charges. en-us Thu, 03 Dec 2009 00:00:00 +0530 Wed, 07 Sep 2011 17:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35156 Charges under a ginning and pressing agreement were treated as composite receipts, because the arrangement included storage facilities in godowns as well as labour and allied operations. A flat attribution of 50% of the charges as rental income was held unsustainable, since the true income element attributable to storage had to be determined by proportional factual allocation rather than a blanket percentage. The court noted that a remand for fresh allocation was impracticable after a long delay, but rejected the mechanical departmental method and indicated that future assessment years should follow proportional apportionment of the composite charges. Case-Laws Income Tax Thu, 03 Dec 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35156