TaxTMI 
TaxTMI 
1981 (11) TMI 17
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....iples laid down by their Lordships of the Supreme Court. The assessee's activity of raising tea, selling tea and also the activity of raising paddy and other crops on the fallow land for the time being constituted an indivisible business. The accounts are all consolidated and the management is the same. There is no separate activity as such. All constitute a single activity. In such a situation, there can be no manner of doubt that the indirect expenses which are incurred in the head office and the branch office relating to the whole activity will have to be allowed in full without bifurcating a Portion on the ground that a portion is relatable to agricultural activity and, therefore, disallowable. Applying the above principles, we have no ....
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....; Rs. 1969-70 579 1970-71 1,157 1971-72 1,542 1972-73 2,120 1973-74 771 -------------------------------------- On this the Revenue wanted a reference and that application was refused by the Tribunal. Then the Revenue made an application under s. 256(2) of the I.....
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....of the Supreme Court in the case of CIT v. Maharashtra Sugar Mills Ltd. [1971] 82 ITR 452. There also the Supreme Court found that growing of "sugarcane and production of sugar" formed an indivisible business of the assessee. There the Supreme Court at p. 454 of the report observed that the finding of the Tribunal that the cultivation of sugarcane as well as the manufacture of sugar constituted one business was a finding of fact and that finding had not been challenged before the court. Precisely the same position prevails here and that is the reason why in the previous year this court on the identical question discharged the rule. We were also not addressed by any argument on the misapplication of the principle by the Tribunal based on thi....