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Documents citing Puthutotam Estates (1943) Ltd. vs Agricutural Income-Tax Officer. on 15 April, 1960

S R Ramakrishnan vs Agricultural Income-Tax Officer, ... on 4 August, 1964

Learned counsel appearing for the petitioner has drawn our attention to the decision of this court in Puthutotam Estates (1943) Ltd. v. Agricultural Income-tax Officer. In that case coffee grown by the assessee was sold to the Coffee Board, but the Coffee Board remitted only a part of the sale proceeds immediately after the sale, and the balance of the sale proceeds was paid in succeeding years. In the view of the Bench of this court, for the purpose of the assessment of agricultural income-tax, the time of the sale was the governing factor because according to the very definition (of agricultural income) the income was derived by the sale of the produce. Therefore, if the sale was made before the 1st of April, 1954, although the proceeds of such sale were received subsequent to April, 1954, such receipts were not taxable in the year of receipt. Therefore, the year of sale is the relevant factor to be taken into account.
Madras High Court Cites 4 - Cited by 2 - Full Document

Beverley Estates Ltd. vs Commissioner Of Agricultural ... on 23 February, 1965

In those cases, the position was that during the year of account April 1, 1954, to March 31, 1955, the assessee had received a certain sum from the Coffee Board relating to the coffee delivered in the years 1952-53 and 1953-54. The company was taxed on the basis of receipt of money from the Coffee Board during the year of account relevant to the first assessment year, though the produce itself related to years earlier than the first year of account in respect of which the Act took effect, Rajagopalan J., who heard the writ petitions, took the view that though the amount was received towards the produce of coffee gathered and sold prior to April 1, 1954, since the amounts were received only in the relevant year of account they were liable to be taken in the computation of the total agricultural income of that year. The receipt of the income was taken to be the basis of liability to tax. An appeal was taken against this decision and a Bench of this court decided in Puthutotam Estates (1943) Ltd. v. Agricultural Income-tax Officer, that if the sale of a coffee crop had taken place after the 1st of April, 1954, the income from such sale would be taxable for the assessment year 1955-56, even though the whole or part of that crop was grown prior to the 1st of April, 1954. But if the sale had taken place before the 1st of April, 1954, the income from such sale would not be taxable, even if the sale price was realised after the 1st of April, 1954. While Rajagopalan J. had taken the view that the date of receipt of the sale value of the coffee was the basis of liability, the Appellate Bench went back one stage further and held that it was the date of sale, that is to say, the delivery of coffee to the Coffee Board, that should be the governing factor for fixing the liability to tax. The Bench further held that it made no difference what system of accounting was adopted by the assessee.
Madras High Court Cites 10 - Cited by 14 - Full Document

State Of Kerala And Others vs Bhavani Tea Produce Co. Ltd on 7 October, 1965

The judgment of Rajgopalan J. was reversed on appeal in Puthuthottam Estates (1943) Ltd., v. Agricultural Income-Tax Officer(1). Rajamannar C.J., and Jagadisan J. held that, if the sale took place after 1st April 1954, tax was payable no matter if the produce was of an earlier year but if the sale took place earlier than that date, tax would not be payable even if the price was realized later. In the Kerala High Court distinction was made between entries under cash and mercantile systems of bookkeeping.
Supreme Court of India Cites 16 - Cited by 17 - S M Sikri - Full Document

R. Vaidyanatha Mudaliar vs State Of Madras on 27 November, 1969

In this system, income would be taxable when actually received, whereas in the mercantile system it would be taxable in the year of receipt or on the date of entry of such receipt--See Puthutotam Estates (1943) Ltd. v. Agricultural Income-tax Officer, [1962] 45 ITR 86 (Mad) and State of Kerala v. Bhavani Tea Produce Co. Ltd., It is not suggested in this case that the entries in the books ever disclosed a cash receipt or disbursement. In fact, there is no suggestion that the produce was ever subject to a sale or a manufacturing process with intention to sell. The entries disclosed only the receipt of income in kind. Even the other entries regarding the refund of advances of paddy are entries in kind. This is one method of accounting of the agricultural produce. The account books are regularly kept and the finding is that they are regularly maintained. The system may be a queer one, but it is an acceptable one. Whether the quantification as made in the books is correct or not is a different matter. At this stage we are concerned with the system of accounting which is infallible besides being properly maintained. The system may evade analysis in the words of an accountant, but it is, as rightly stated, a hybrid one. Nevertheless the method cannot be disregarded and a badge of mis-description implanted on it to call it a cash system of accounting. We are, therefore, of the view that it is not a cash system as is commonly and legally understood, but it is a system which is regularly employed by the assessee and it is on this system that agricultural income shall be computed for purposes of the Act.
Madras High Court Cites 9 - Cited by 3 - Full Document
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