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TMI Blog2015 (9) TMI 1409X X X X Extracts X X X X X X X X Extracts X X X X ..... admitted on the following substantial questions of law: "(a) Whether on a true and proper interpretation of Section 80 HHC of the Income Tax Act, 1961 the Tribunal was justified in not allowing the deduction under section 80HHC of the Income Tax Act, 1961 in computing the mixed income derived from the tea grown and manufactured by the assessee and thereafter in proceeding under Rule 8 of the In ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llowed while computing the income derived from sale of tea grown and manufactured by the seller which form the composite income from sale of tea grown and manufactured by the seller and the apportionment in terms of Rule 8 of the Income Tax Rules, 1962 between agricultural income and nonagricultural income should be made after the said deduction is allowed in the computation of composite income ?" ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... answered in the affirmative, in favour of the respondent/revenue and against the appellant/assessee. The question no.(b) is also answered in the affirmative, in favour of the respondent/revenue and against the appellant/assessee. So far as the question no.(c) is concerned, in view of the unreported judgment delivered on 19th May, 2011 in ITA 651 of 2004 [ Goodricke Group Ltd. vs. Commissioner of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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