1987 (3) TMI 47 - HC - Income Tax

Summary

Issues: Valuation of sugarcane produced by the assessee in its own farms for the purpose of ascertaining manufacturing profits for assessment years 1957-58, 1958-59, 1959-60, and 1960-61.

Analysis:

The judgment pertains to a reference sought under section 256(2) of the Income-tax Act, 1961, regarding the valuation of sugarcane produced by the assessee in its own farms. The question raised was whether the Tribunal erred in valuing the sugarcane at Rs. 44, Rs. 45, Rs. 46, and Rs. 47 per ton instead of the claimed Rs. 51.75 per ton for the assessment years 1957-58, 1958-59, 1959-60, and 1960-61. The Government of Maharashtra had set floor prices for sugarcane, which the assessee paid to outside cultivators. However, the assessee claimed a higher rate for the sugarcane grown on its own farms. The Income-tax Officer and the Appellate Assistant Commissioner rejected the higher rate, leading to an appeal to the Income-tax Appellate Tribunal.

The Tribunal, in its order, considered various aspects, including the purity percentages of the sugarcane and the prices paid to outside suppliers. It noted discrepancies in the claimed higher rate and the actual data available. The Tribunal found that the prices paid to outside suppliers could represent the market value for the assessee's own sugarcane. It directed the modification of agricultural profit based on these averages. The assessee contended that the Tribunal's decision was flawed due to not considering certain aspects like price differentials based on purity percentage, analysis reports, and certificates from associations.

The Tribunal's decision was upheld, emphasizing that the price differentials were not adequately supported by data. The analysis reports and certificates provided by the assessee did not alter the Tribunal's view. The certificate from the Deccan Sugar Factories Association was deemed insufficient to justify the higher rate claimed by the assessee. Ultimately, the Court found no reason to interfere with the Tribunal's decision, ruling in favor of the Revenue and ordering the assessee to bear the costs of the reference.