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Calcutta High Court

Commissioner Of Income Tax vs M/S. Narsingpore Tea Co. Pvt.Ltd on 20 December, 2010

Author: Kalyan Jyoti Sengupta

Bench: Kalyan Jyoti Sengupta

                                  ITAT No. 219 OF 2010
                                   GA No.3120 of 2010

                         IN THE HIGH COURT AT CALCUTTA
                        SPECIAL JURISDICTION (INCOME TAX)
                                  ORIGINAL SIDE

                     COMMISSIONER OF INCOME TAX, KOLKATA-II

                                         Versus

                        M/S. NARSINGPORE TEA CO. PVT.LTD.



  BEFORE:

  The Hon'ble JUSTICE KALYAN JYOTI SENGUPTA

  The Hon'ble JUSTICE KANCHAN CHAKRABORTY

  Date : 20th December, 2010.


            The Court :- The appeal in relation to assessment year 2003-04 is
admitted on the following substantial questions of law;-
              i)       Whether the Income Tax Appellate Tribunal erred in law in not
                       holding that the cess on green leaf is not allowable as deduction
                       from composite income before computation of income chargeable
                       to tax ?
              ii)      Whether the Income Tax Appellate Tribunal was justified in
                       holding that cess on green leaf is allowable deduction from
                       composite income whereas Rs.17,03,915/- is the expenses related
                       to 100% agricultural operation and, therefore, the decision of
                       Income Tax Appellate Tribunal is perverse ?
              iii)     Whether the Income Tax Appellate Tribunal erred in law in
                       allowing depreciation of Rs.1,49,785/- under Section 33AB(6) of
                       the Income Tax Act, 1961 relying on the decision of the Hon'ble
                                            2


                    Income Tax Appellate Tribunal in the case of (C.I.T. Vs. Goodrick
                    Group Ltd.) ignoring the decision of the jurisdictional High Court
                    reported in 137 ITR 827 and 1348 ITR 68 and as such whether
                    the decision of this   Income Tax Appellate Tribunal is at all
                    sustainable ?
            The appellant shall file requisite number of paper books within two
months after Christmas Vacation.
           Let Notice-of-Appeal be served upon the respondents by the Department

concerned on usual course.

Accordingly the application is disposed of. All parties concerned are to act on a photostat signed copy of this order on the usual undertakings.

(KALYAN JYOTI SENGUPTA, J.) (KANCHAN CHAKRABORTY, J.) GH.