{"id":44208,"date":"1971-08-16T00:00:00","date_gmt":"1971-08-15T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-maharashtra-sugar-mills-ltd-on-16-august-1971"},"modified":"2015-10-23T07:29:46","modified_gmt":"2015-10-23T01:59:46","slug":"commissioner-of-income-tax-vs-maharashtra-sugar-mills-ltd-on-16-august-1971","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-maharashtra-sugar-mills-ltd-on-16-august-1971","title":{"rendered":"Commissioner Of Income-Tax … vs Maharashtra Sugar Mills Ltd. … on 16 August, 1971"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Commissioner Of Income-Tax … vs Maharashtra Sugar Mills Ltd. … on 16 August, 1971<\/div>\n
Equivalent citations: 1971 AIR 2434, \t\t 1972 SCR (1) 202<\/div>\n
Author: K Hegde<\/div>\n
Bench: Hegde, K.S.<\/div>\n
           PETITIONER:\nCOMMISSIONER OF INCOME-TAX BOMBAY\n\n\tVs.\n\nRESPONDENT:\nMAHARASHTRA SUGAR MILLS LTD.  BOMBAY\n\nDATE OF JUDGMENT16\/08\/1971\n\nBENCH:\nHEGDE, K.S.\nBENCH:\nHEGDE, K.S.\nGROVER, A.N.\n\nCITATION:\n 1971 AIR 2434\t\t  1972 SCR  (1) 202\n\n\nACT:\nIncome-tax Act (11 of 1922), s. 10(2)(xv) and r. 23 of Rules\n--Part\tof assessee's income not exigible to  tax-Commission\nto  managing  agent-Whether part of commission\trelating  to\nsuch income not deductible from assessee's gross profits.\n\n\n\nHEADNOTE:\nThe assessee was a limited company. it owned extensive lands\nin  which sugar cane was grown and the cane was used by\t the\nassessee  for the manufacture of sugar in its factory.\t The\ncultivation  of sugar cane and the manufacture of  sugar  by\nthe   assessee\tconstituted  one  single   and\t indivisible\nbusiness.   In\tthe assessment year  1957:58,  the  assessee\nclaimed\t deduction  of\tremuneration paid  to  its  managing\nagents under s.10(2)(xv) of the Indian Income-tax Act, 1922,\nas  an\titem of expenditure laid out or expended  wholly  or\nexclusively for the purpose of its business.  The Income-tax\nOfficer and the Appellate Assistant Commissioner  disallowed\na  part of the remuneration on the grounds that part of\t the\nassessee's business namely cultivation of sugar cane,  being\nan  agricultural  operation, the income\t therefrom  was\t not\nexigible to tax, and therefore, any expenditure incurred  in\nrespect\t of that activity was not deductible.  The  Tribunal\nand the High Court on reference, however, upheld the plea of\nthe assessee that the entire sum was deductible.\nDismissing the appeal to this Court,\nHELD:\t  (1)  The  mandate  of s. 10(2)(xv)  is  plain\t and\nunambiguous.   To  find out whether a deduction\t claimed  is\npermissible under the Act or not, all that the Court has  to\ndo  is\tto  examine  the relevant  provisions  of  the\tAct.\nEquitable considerations are wholly out of the place in con-\nstruing\t the  provisions  of the  taxing  statute.   If\t the\nallowance  claimed is permissible under the Act then it\t has\nto  be deducted from the grow profits, and if it is  not  so\npermissible it has to be rejected. [232 H; 233 A-D]\n In the. present case, the allowance claimed was undoubtedly\nlaid out or expended for the purpose of the business carried\non by assessee.\t The fact that income arising from a part of\nthat business was not exigible to tax under the Act was\t not\na relevant circumstance. [233 D-E]\nC.I.T.,\t Bombay v. Parakh and (India) Ltd.,<\/a> 29 I.T.R.,\t661,\nand  C.L  T.  Madras  v. Indian Bank  Ltd.,  56\t I.T.R.\t 79,\nfollowed.\nS.A.S.S.  Chellappa Chettiar v. C.I.T, Madras, 5 I.T.R.,  97\nand Salt & Industries Agencies Ltd.  Bombay v. C.LT., Bombay\nCity, 18 I.T.R. 58, referred to.\n(2)  Rule  23 of the rules framed under the  Income-tax\t Act\nsays that in computing the taxable income of a business\t the\nagricultural income as defined in s. 2 of the Act should  be\ndeducted from the tota\n 231\nincome for arriving at the taxable income.  The rule further\nsays  that  No\tfurther\t deduction  shall  be  made  of\t any\nexpenditure  incurred  by  the\tassessee  as  cultivator  or\nreceiver of rent in kind'.  If the rule is read with s. 2(1)\nit  is clear that reference to the expenditure\tincurred  by\nthe  assessee  as a cultivator only applies to\tthe  process\nordinarily employed by a cultivator in raising the crops and\nall other incidental and supple mentary activities up to the\nstage  of  sale of the produce, and has nothing to  do\twith\ndisbursements such as payment of managing agency commission.\n[238E-H; 24OA-B]\n\n\n\nJUDGMENT:\n<\/pre>\n
CIVIL  APPELLATE  JURISDICTION : Civil Appeal  No.  1658  of
\n1968.\n<\/p>\n
Appeal\tby special leave from the judgment and\torder  dated
\nSeptember  22, 1967 of the Bombay High Court  in  Income-tax
\nReference No. 83 of 1962.\n<\/p>\n
B.   D. Sharma, and R. N. Sachthey, for the appellant
\nV.   Rajagopal, M. M. Vakil, B. Datta, J. B. Dadachanji,
\nO.   C. Mathur and Ravinder Narain, for the respondent.
\nThe Judgment of the Court was delivered by
\nHegde,\tJ.  This is an appeal by special leave.\t  It  arises
\nfrom  the  decision of the Bombay High Court  in  Income-tax
\nReference  No. 83 of 1962 on its file.\tThat  Reference\t was
\nmade  by  the  Income-tax  Appellate  Tribunal,\t Bench\t‘B’,
\nBombay.\t  The  question of law which was referred  for\tthe.
\nopinion\t of  the  High Court under  s.66(1)  of\t the  Indian
\nIncome-tax  Act, 1922 (to be hereinafter referred to as\t the
\nAct) is:\n<\/p>\n
\t      “Whether on the facts and in the circumstances\n<\/p><\/blockquote>\n
\t      -of this case the Department could disallow  a
\n\t      sum  of  Rs.  1,26,359\/-\ta  portion  of\t the
\n\t      managing\t agency\t ,commission  paid  by\t the
\n\t      assessee\tcompany\t for  the  ,assessment\tyear
\n\t      1957-58 in computing the income from  business
\n\t      of the assessee company.”\n<\/p><\/blockquote>\n
The  assessee  is M\/s.\tMaharashtra Sugar  Mills  Ltd.\t The
\nconcerned  assessment  year is\t1957-58,  the  corresponding
\naccount\t year  ending  on 30-9-1956. ,\tThe  assessee  is  a
\nLimited\t Company. it carries on business of  manufacture  of
\nsugar  from.sugar  cane.  It owns extensive lands  in  which
\nsugar cane is grown.  The sugar cane grown in these lands is
\nused  by  the  assessee\t for manufacture  of  sugar  in\t its
\nfactory.  The finding of the Tribunal is that
\n16-M 1245 Sup.\tCl\/71
\n232<\/span>
\nthe  cultivation of sugar cane and the manufacture of  sugar
\nby  the\t assessee  constitute  one  single  and\t indivisible
\nbusiness.   The\t assessee  company is  managed\tby  managing
\nagents.\t  The  managing\t agents were  paid  remuneration  in
\naccordance  with  the  agreement entered  into\tbetween\t the
\nassessee  company  and\tthe managing  agents;  The  managing
\nagents’s commission roughly worked out at 10 percent of\t the
\nprofits of the company.\t In the assessment year in  question
\nthe  managing  agents were entitled to a commission  of\t Rs.
\n4,86,228 \/6 \/-.\t In its assessment proceedings, the assessee
\nclaimed\t deduction of this sum under s.10(2)(15) as an\titem
\nof  expenditure laid out or expended wholly  or\t exclusively
\nfor  the  purpose  of its business.  Out of  that  sum,\t the
\nIncome-tax Officer disallowed a sum of Rs. 1,26,359\/- on the
\nground\tthat  the  same relates to  the\t commission  of\t the
\nmanaging agents for managing the sugar cane cultivation part
\nof  the\t business.   In\t appeal,  the  Appellate   Assistant
\nCommissioner concurred with the view taken by the Income-tax
\nOfficer.   The assessee took up the matter in second  appeal
\nto  the Income-tax Appellate Tribunal.\tThe Tribunal  upheld
\nthe  plea of the assessee that the entire sum is  deductible
\nunder S. 10(2) (15).  It also rejected the contention of the
\ndepartment  that  on the facts of the case rule\t 23  of\t the
\nRules framed under the Act is applicable.  In the  Reference\n<\/p>\n
-referred to earlier, the High Court agreeing with the view.
\ntaken by the Tribunal answered the question in favour of the
\nassessee.  Hence this appeal.\n<\/p>\n
The  finding of the Tribunal that the cultivation  of  sugar
\ncane  as  well as the manufacture of sugar  constitutes\t one
\nbusiness  is a finding of fact.\t That finding has  not\tbeen
\nchallenged  before  us\tWhat. was urged\t on  behalf  of\t the
\ndepartment is that the assessee’s business consisted of\t two
\nparts\tnamely\t(1)  cultivation  of  sugar  cane  and\t the
\nmanufacture  of sugar.\tThe former part\t being\tagricultural
\noperation,  the income therefrom is not exigible to tax\t and
\ntherefore  any\texpenditure  incurred  in  respect  of\tthat
\nactivity is not deductable.  This contention proceeds on the
\nbasis  that  only  expenditure\tincurred  in  respect  of  a
\nbusiness  activity  giving rise to income, profit  or  gains
\ntaxable\t under\tthe Act can be given deduction\tto  and\t not
\notherwise.   We see no basis for this contention.   To\tfind
\nout whether a deduction claimed is permissible under the Act
\nor  not, all that we have to do is to examine  the  relevant
\nprovisions of
\n233<\/span>
\nthe  Act.  Equitable considerations are wholly out of  place
\nin construing the  provisions of a taxing statute.  We\thave
\nto take the provisions of the statute as they stand.  If the
\nallowance claimed is permissible under the Act then the same
\nhas  to\t be deducted from the gross profit.  If\t it  is\t not
\npermissible  under the Act, it has to be rejected.  As\tmen-
\ntioned\tearlier, it is not disputed that the cultivation  of
\nsugar  cane  and the manufacture of  sugar  constituted\t one
\nsingle\tand indivisible business.  Section 10(2)  says\tthat
\nprofits\t under S. 10(1) in respect of a business  should  be
\ncomputed  after deducting the allowances mentioned  therein.
\nOne  of the allowances allowed is that mentioned in  s.10(2)\n<\/p>\n
(xv)  which says that any expenditure laid out\tor  expended
\nwholly\tand  exclusively for the purpose  of  such  business
\nshall  be  deducted as an allowance.  The mandate  of  s  10
\n(2)(15) is plain and unambiguous.  Undoubtedly the allowance
\nclaimed\t in  this  case was laid out  or  expended  for\t the
\npurpose\t of  the business carried on by the  assessee.\t The
\nfact that the income arising from a part of that business is
\nnot exigible to tax under the Act is not a relevant  circum-
\nstance.\t  For the foregoing reasons we agree with  the\tview
\ntaken by the High Court.\n<\/p>\n
Turning\t now to the decided cases, we shall first  refer  to
\nthe  decision  of  the\tMadras High  Court  in\tS.  A.\tS.S.
\nChellappa Chettiar v. Commissioner of Income-tax, Madras<\/a>( 1)
\nThe  facts of that case are, : The assessee was carrying  on
\nthe business of money lending in Burma.\t For the purpose  of
\nthat business he was borrowing money from others at a  lower
\nrate of interest and advancing loans to his- constituents at
\na  higher  rate.   In the course of  his  business,  he\t was
\nobliged\t to receive agricultural lands in repayment  of\t his
\ndebts  from  some of his constituents.\t In  his  assessment
\nproceedings  he claimed deduction of the interest  David  by
\nhim  in\t respect  of  his borrowings.\tPart  of  the  money
\nborrowed  by him had been advanced to constituents  who,  as
\nmentioned earlier, had made over their agricultural lands to
\nthe assessee.  The question arose whether the interest\tpaid
\nin  respect of the money advanced to those constituents\t was
\ndeductable  in\tcomputing  the\tprofits\t and  gains  of\t the
\nassessee.   The High Court held that he was entitled to\t the
\ndeduction  claimed  and\t further he  was  also\tentitled  to
\ndeduction in
\n(1)  5 I.T. P,. 97.\n<\/p>\n
234<\/span><\/p>\n
respect\t of the establishment and other charges incurred  by
\nhim  for managing and cultivating such lands and the  amount
\nspent for obtaining conveyances of such lands.
\nSir H. O. C. Beasley C. J., speaking for the Court observed:\n<\/p>\n
\t      “It seems to us that the governing section  in
\n\t      order  to\t decide\t this matter  must  be\tSec.
\n\t      10(2)(iii).  Was the capital borrowed for\t the
\n\t      purpose  of  the\tassessee’s  business  ?\t  No
\n\t      difficulty  arises  about\t that,\tfor  it\t  is
\n\t      ,conceded\t that  it was so borrowed.   It\t was
\n\t      also  unquestionably used for the\t purpose  of
\n\t      the business because it is again conceded that
\n\t      it  was  lent  to\t the  borrowers.   Does\t  it
\n\t      continue to be so used ? It is in that respect
\n\t      that  it is important again to emphasise\tthat
\n\t      this  case has been argued, before us  on\t the
\n\t      basis  that  these lands came  into  and\twere
\n\t      retained in the possession of the assessee  in
\n\t      payment\tof  a  moneylending  debt  and\t ex-
\n\t      necessitate.”\n<\/p><\/blockquote>\n
The test applied by the learned Chief Justice appears to  us
\nto be the correct one.\n<\/p>\n
We shall next take up the decision of the Bombay High  Court
\nin Salt and Industries Agencies Ltd., Bombay v. Commissioner
\nof  Income-tax, Bombay City<\/a> (1).  The assessee in that\tcase
\nwas  a\tcompany\t incorporated  in  Bombay.   They  were\t the
\nmanaging   agents   of\tanother\t company  which\t  was\talso
\nincorporated  in Bombay.  The managed company  had  business
\nboth in British India as well as in the Indian States.\t The
\nprofits arising from the business activities of the  managed
\ncompany in the Indian States was not exigible to tax but yet
\nthe assessee claimed that a part of the commission earned by
\nit  being in respect of business carried on outside  British
\nIndia, the same could not be considered as an income  earned
\nin British India.  That contention was rejected by the\tHigh
\nCourt.\t In  the  course of its\t judgment,  the\t High  Court
\nobserved:\n<\/p>\n
\t      “It  is  perfectly  true that as\tfar  as\t the
\n\t      parent company is concerned, the profits\tmade
\n\t      at  Kandla  could be said to have\t arisen\t and
\n\t      accrued at Kandla, but as far as the  managing
\n\t      agents  are  concerned, their  commission\t has
\n\t      nothing whatever to do with those profits.
\n\t      (1)   18 L.T.R. 58.\n<\/p><\/blockquote>\n
\t      Their  commission is only concerned  with\t the
\n\t      ultimate determination of all the workings  of
\n\t      the  company and the finding out\twhether\t and
\n\t      what  profits has been earned by the  company.
\n\t      It cannot be said that as profits were  earned
\n\t      by the parent company, the commission also was
\n\t      accruing or arising to the managing agents.” –\n<\/p><\/blockquote>\n
In  Commissioner  of Income-tax, Bombay v. C  Parakh  &\t Co.
\n(India)\t Ltd.\tI. The<\/a> ratio of that decision bears  on\t the
\nquestion  of  law  that we are\tconsidering.   The  assessee
\ncompany\t therein  was resident and  ordinarily\tresident  in
\nIndia.\t It had its head office in Bombay.  It maintained  a
\nbranch\tat  Karachi for purchasing cotton  for\tshipment  to
\nBombay\tor to export direct to other places.’ By  an  agree-
\nment,  the  managing  agents of the  assessee  company\twere
\nentitled  to a remuneration of 20 percent of the annual\t net
\nprofits\t of  the  assessee company to  ascertain  which\t the
\nresult of the trade in all its branches had to be taken into
\naccount.   The\tassessee  apportioned  the  managing  agency
\ncommission  and\t debited  the proportionate  amount  in\t the
\nrespective  profit  and\t loss account for  the\tBombay\thead
\noffice\tand the Karachi branch.\t In computing  the  Pakistan
\nincome\tof the assessee for the purpose of  double  taxation
\nrelief\tthe Income-tax Officer deducted from the  income  of
\nthe   Karachi  branch  the  proportionate  managing   agency
\ncommission.  The Appellate Assistant Commissioner  confirmed
\nthat  order  but  the  Tribunal and  the  High\tCourt  on  a
\nreference  held that the managing agency commission  in\t its
\nentirety should be debited to the Bombay branch.  On  appeal
\nthis  Court held that the entire managing agency  commission
\nwas  liable  to be debited against the\tIndian\tprofits\t and
\nfurther assessee company could not be estopped from claiming
\nthe benefit of such deduction by reason: of the fact that it
\nerroneously allocated a part of it toward the profits earned
\nin  Karachi.   In  the course of; its  judgment\t this  Court
\nobserved:\n<\/p>\n
\t      “Section\t10(2)(xv) of the  Indian  Income-tax
\n\t      Act provides that in computing the profits  of
\n\t      a\t business  allowance is to be made  for\t any
\n\t      expenditure  laid out or expended\t wholly\t and
\n\t      exclusively for the purpose of such business..
\n\t      Now the respondent is carrying on
\n\t      (1)   29 I.T.R. 661.<\/p><\/blockquote>\n
\t      236<\/span><\/p>\n
\t      business\tin  cotton  both  in  India  and  in
\n\t      Karachi.\tWhen an assessee carries on the same
\n\t      business\tat a number of places there  is\t for
\n\t      the  purpose of section 10 ,only one  business
\n\t      and the net profits of the business have to be
\n\t\t\t    ascertained\t by  pooling together  the
\n  profits
\n\t      ,earned  in  all the, branches  and  deducting
\n\t      therefrom\t all  the expenses.  The  fact\tthat
\n\t      some   of\t  the  branches\t  are\tin   foreign
\n\t      territories  will\t make no difference  in\t the
\n\t      position if the assessee is as in the  present
\n\t      case  resident and ordinarily resident  within
\n\t      the   taxable  territories.    Therefore\t the
\n\t      profits earned in India and in Karachi have to
\n\t      be thrown together and the expenses  including
\n\t      the commission payable to the managing  agents
\n\t      deducted\ttherefrom and it is the net  profits
\n\t      thus  struck that become chargeable under\t the
\n\t      Act.   That is how the Income-tax Officer\t has
\n\t      worked  out  the figures.\t The  respondent  is
\n\t      therefore\t clearly entitled to a deduction  of
\n\t      the  whole of the commission of  Rs.  3,12,699
\n\t      paid to the managing agents including the\t sum
\n\t      of Rs. 1,23,719 against the Indian profits.”
\nLastly we refer to the decision of this Court in Co  mission
\nof  Income-tax\tMadras v. Indian Bank  Ltd(1).\tTherein\t the
\nrespondent,  a\tbanking\t company,  in  the  course  of\t its
\nbusiness,  invested  a large sum  in  securities,  including
\nsecurities  the\t interest  on which  was  exempt  from\ttax.
\nProfits\t and  losses  on  the  purchase\t and  sale  of\tsuch
\nsecurities  were  duly taken into account in  computing\t the
\nbusiness  income  of  the  respondent.\t The%  question\t for
\ndecision was whether the interest paid by the respondent  on
\nthe  amount invested in securities, whose interest  was\t tax
\nfree,  was  deductable from its gross profits.\t This  Court
\nheld that interest paid by the respondent on moneys borrowed
\nfrom  its  various  depositors\thad to\tbe  allowed  in\t its
\nentirety  under S. 10(2) (iii) of the Act and there  was  no
\nwarrant for disallowing a proportionate part of the interest
\nreferable  to money borrowed for the purchase of  securities
\nwhose interest was tax-free.  In the course of the  Judgment
\nSubba Rao, J. (as he then was) observed:\n<\/p>\n
\t      “In  our opinion,, in construing the  Act,  we
\n\t      must  adhere  closely to the language  of\t the
\n\t      Act.  If there is ambiguity in the terms of  a
\n\t      provision, recourse must
\n\t      (1)   56 I.T.R. 79.\n<\/p><\/blockquote>\n
\t      237<\/span><\/p>\n
\t      naturally\t   be\thad   to    well-established
\n\t      principles  of  construction  but\t it  is\t not
\n\t      permissible  first  to  create  an  artificial
\n\t      ambiguity\t  and  then  try  to   resolve\t the
\n\t      ambiguity by resort to some general principle.\n<\/p><\/blockquote>\n
We  are\t concerned with the interpretation of  section,\t 10.
\nLet  us then look at the language employed. Sub-section\t (1)
\ndirects that an assessee be taxed in respect of the  profits
\nand  gains  of\tbusiness carried on by\thim.   What  is\t the
\nbusiness  of the assessee must first be looked at.  Does  he
\ncarry  on one business or two businesses or along  with\t the
\nbusiness  carried  on by him some activity  which  is\/not  a
\nbusiness  ?  If he is carrying on an activity which  is\t not
\nbusiness, we must leave out of account the receipts of\tthat
\nactivity.   That is the first step.  Secondly, we must\tlook
\nat section 10(2) and deduct all the allowances permission    ale
\nto  him.  In allowing a deduction which is  permissible\t the
\nquestion arises: Do we look behind the ,expenditure and\t see
\nwhether\t it  has  the quality  of  ,directly  or  indirectly
\nproducing  taxable  income  ?  ‘The answer must\t be  in\t the
\nnegative for two reasons: First, Parliament has not directed
\nus to undertake this\t enquiry.   There  are no  words  in
\nsection\t  10(2)\t to  that  effect.   On\t the   other   hand,
\nindications are to the contrary.  In Section 10(2)(xv), what
\nParliament  requires  to  be  ascertained  is  whether\t the
\nexpenditure  has  been\tlaid  out  or  expended\t wholly\t and
\nexclusively   for   the\t purpose  of  the   business.\t The
\nlegislature    stops   short   at  directing  that   it\t  be
\nascertained what was the purpose of the expenditure.  If the
\nanswer\tis  that  ,it is for the purpose  of  the  business,
\nParliament  is\tnot  concerned\tto  find  out  whether\t the
\nexpenditure  has  produced or will produce  taxable  income.
\nSecondly,  the reason may well- be that\t Parliament  assumes
\nthat most types of expenditure which are laid out wholly and
\nexclusively  for the purpose of business would\tdirectly  or
\nindirectly  produce taxable income, and it is not worth\t the
\nadministrative\teffort involved to go further and trace\t the
\nexpenditure to some taxable income.”\n<\/p>\n
On behalf of the department reliance was sought to be placed
\non the decision of this Court in Badridas Doga v.\n<\/p>\n
238<\/span><\/p>\n
Commissioner  of Income-tax(1).\t The ratio of that  decision
\ndoes  not  bear on the issue arising for  decision  in\tthis
\ncase.\tThat decision is wholly irrelevant for\tour  present
\npurpose
\n It was next urged on behalf of the department that in\tview
\nof  rule 23 of the Rules framed, it was permissible for\t the
\nIncome-tax  Officer to split up the commission given to\t the
\nmanaging agents.  We see no merit in this contention.\tRule
\n23 to the extent material for our present purpose reads:\n<\/p>\n
\t      “23(1)   In  the\tcase  of  Income  which\t  is
\n\t      partially\t agricultural income as\t defined  in
\n\t      section  2 and partially income chargeable  to
\n\t      income-tax   under  the  head  “business”\t  in
\n\t      determining  that part which is chargeable  to
\n\t      income-tax    the\t  market   value   of\t any
\n\t      agricultural produce which has been raised  by
\n\t      the  assessee  or received by him as  rent  in
\n\t      kind  and\t which\thas  been  utilised  as\t raw
\n\t      material in such business or the sale receipts
\n\t      of  which are included in the accounts of\t the
\n\t      business\tshall  be deducted, and\t no  further
\n\t      deduction\t shall\tbe made in  respect  of\t any
\n\t      expenditure  incurred  by the  assessee  as  a
\n\t      cultivator or receiver of rent in kind.”\n<\/p><\/blockquote>\n
Rule 23 lays down the method of computing the taxable income
\nof  a business which partly arises from the  utilisation  of
\nagricultural  produce as raw material in the  business.\t  It
\nsays  that  in computing the  taxable  income,\tagricultural
\nincome as defined in S. 2 of the Act should be deducted from
\nthe  total income for arriving at the taxable  income.\t For
\ndetermining  what the agricultural income is the  Income-tax
\nOfficer must determine the market value of the\tagricultural
\nproduce\t used  as raw material in the  business.   The\trule
\nfurther says that “no further deduction shall be made of any
\nexpenditure  incurred  by the assessee as  a  cultivator  or
\nreceiver of rent in kind.” (emphasis supplied).
\nThe managing agency commission given to the assesses is\t not
\nan  expenditure incurred by the assessee as a cultivator  or
\nas a receiver of the rent in kind.  The last part of subrule
\n(1)  of\t Rule  23 merely  stipulates  that  the\t expenditure
\nincurred  by the assessee for his agricultural operation  or
\nincurred  by  him as receiver of rent in kind is not  to  be
\ndeducted while arriving at the taxable income.\tSection
\n(1)  34 I.T.R. 10.\n<\/p>\n
 239<\/span><\/p>\n
2(1)  of the Act defines agricultural income.  That  section
\nreads:\n<\/p>\n
“agricultural income” means-\n<\/p>\n
\t      (a)   any\t rent or revenue derived  from\tland
\n\t      which  is used for agricultural purposes,\t and
\n\t      is  either  assessed to  land-revenue  in\t the
\n\t      taxable territories or subject to a local rate
\n\t      assessed\tand  collected by  officers  of\t the
\n\t      Government as such;\n<\/p><\/blockquote>\n
\t      (b)   any income derived from such land by-\n<\/p><\/blockquote>\n
\t      (i)   agricultural or\n<\/p><\/blockquote>\n
\t      (ii)  the\t performance  by  a  cultivator\t  or
\n\t      receiver\tof  rent  in  kind  of\tany  process
\n\t      ordinarily   employed  by\t a.  cultivator\t  or
\n\t      receiver of rent-in-kind to render the produce
\n\t      raised  or received by him fit to be taken  to
\n\t      market, or\n<\/p><\/blockquote>\n
\t      (iii) the sale by a cultivator or receiver  of
\n\t      rent-in-kind of the produce raised or received
\n\t      by  him,\tin respect of which no\tprocess\t has
\n\t      been  performed  other than a process  of\t the
\n\t      nature described in sub-clause (ii).<\/p><\/blockquote>\n
\t      (c)   any\t income\t derived from  any  building
\n\t      owned and occupied by the receiver of the rent
\n\t      or  revenue of any such land, or\toccupied  by
\n\t      the  cultivator,\tor the receiver of  rent  in
\n\t      kind, of any land with respect to , which,  or
\n\t      the  produce of which any operation  mentioned
\n\t\t\t    in sub-clauses (ii) and (iii) of claus
\ne (b)  is
\n\t      carried on:\n<\/p>\n
\t      Provided\tthat the building is on’ or  in\t the
\n\t      immediate\t vicinity  of  the land,  and  is  a
\n\t      building\twhich  the receiver of the  rent  or
\n\t      revenue  or the cultivator or the receiver  of
\n\t      the  rent-in-kind by reason of his  connection
\n\t      with  the land, requires as a dwelling  house,
\n\t      or as a storehouse, or other out-building,”\n<\/p>\n
240<\/span><\/p>\n
If  rule  23 is read along with S. 2(1), it  is\t clear\tthat
\nPreference  to,\t expenditure incurred by the assessee  as  a\n<\/p>\n
-cultivator applies to the process ordinarily employed\tby,a
\ncultivator in raising the crops and all other incidental and
\nsupplementary  activities  upto\t the stage of  sale  of\t the
\nproduce.’  That\t rule has nothing to do\t with  disbursements
\nsuch as payment of managing agency commission.
\nIn  the result this appeal fails and the same  is  dismissed
\nwith costs.\n<\/p>\n
V.P.S.\t\t\t\t      Appeal dismissed.\n241<\/span>\n\n\n\n<\/pre>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Commissioner Of Income-Tax … vs Maharashtra Sugar Mills Ltd. … on 16 August, 1971 Equivalent citations: 1971 AIR 2434, 1972 SCR (1) 202 Author: K Hegde Bench: Hegde, K.S. PETITIONER: COMMISSIONER OF INCOME-TAX BOMBAY Vs. RESPONDENT: MAHARASHTRA SUGAR MILLS LTD. BOMBAY DATE OF JUDGMENT16\/08\/1971 BENCH: HEGDE, K.S. BENCH: HEGDE, K.S. GROVER, […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-44208","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nCommissioner Of Income-Tax ... vs Maharashtra Sugar Mills Ltd. ... on 16 August, 1971 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-maharashtra-sugar-mills-ltd-on-16-august-1971\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Commissioner Of Income-Tax ... vs Maharashtra Sugar Mills Ltd. ... on 16 August, 1971 - 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