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Calcutta High Court

Commissioner Of Income Tax vs Ganeshbari Tea Co. (P) Ltd on 7 September, 2015

Author: Soumitra Pal

Bench: Soumitra Pal

ORDER SHEET

                          IN THE HIGH COURT AT CALCUTTA

                              Special Jurisdiction

                                  ORIGINAL SIDE


                                  ITA 20 of 2010


                  COMMISSIONER OF INCOME TAX, KOLKATA-II,KOLKATA

                                       Versus

                           GANESHBARI TEA CO. (P) LTD.


    BEFORE:

    The Hon'ble JUSTICE SOUMITRA PAL

    The Hon'ble JUSTICE MIR DARA SHEKO

    Date : 7th September, 2015.


                                                          Mr. M. P.Agarwal, Adv.


              The Court : This appeal, preferred under Section 260A of the

    Income Tax Act, 1961 against the order dated 21st August, 2009 passed

    by the Income Tax Appellate Tribunal "C" Bench, Kolkata in ITA No.

    1009(Kol)of 2008 for the assessment year 2005-06, was admitted on

    the following substantial question :



              "   Whether, on the facts and in circumstances of the case,

                  the Income-tax Appellate Tribunal is correct in deleting

                  the disallowance of cess on green tea leaves amounting

                  to Rs.7,49,577 in view of the decision of the Hon'ble

                  Gauhati High Court in case of Jorhat Group Ltd. v. AITO

                  226 ITR 622?"
                                        2




                 It is submitted by Mr. Agarwal, the learned advocate for

     the   appellant   that    the   issue   stands   covered    against   the

     appellant/revenue in view of the order of the Supreme Court dated 6th

     August, 2015 passed in Civil Appeal No.1105 of 2006 [ Commissioner

     of Income Tax vs. M/s. Apeejay Tea Co. Ltd.] wherein the Supreme

     Court of India, after considering the scope of Rule 8, had held that

     the High Court had rightly interpreted the scope of Rule 8 of the

     Income Tax Rules, 1962.

                 We find since the issue stands covered by the order of

     the Supreme Court dated 6th August, 2015 passed in Civil Appeal

     No.1105 of 2006 [ Commissioner of Income Tax vs. M/s. Apeejay Tea

     Co. Ltd.] in favour of the assessee, the question          is answered in

     the affirmative, against the appellant/revenue and in favour of the

     respondent/assessee.

The appeal is dismissed.

(SOUMITRA PAL, J.) (MIR DARA SHEKO, J.) sm