CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd.

224 ITR 605Supreme Court of India1997#4773 most cited

What is CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd. authority for?

Gross total income must be computed by setting off losses, including brought-forward losses and unabsorbed depreciation, before any deductions under Chapter VI-A can be considered. Deductions under Chapter VI-A are only available if the resulting gross total income is positive.

25

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2007 to 2024.

Also referred to as

CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd · section 80A · section 80AB · Chapter VI-A deductions · gross total income · brought forward losses · unabsorbed depreciation · positive income

Sections most often in play

Section 80-I(1)Section 80-I(6)Section 80A(2)Section 80ABSection 80B(5)

Issues it is cited on

section 80esection 32(2)section 80absection 75convertible foreign exchangesection 80msection 32ainitial assessment yearsection 80asection 80jsection 80heligible business

Judgments citing CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd.

MEDLEY PHARMACEUTICALS LTD.,MUMBAI vs. DY.C.I.T., CENT.CIR.44, MUMBAI

In the result, the captioned appeals filed by the assessee are allowed

ITA 1387/MUM/2009[2002-2003]Status: DisposedITAT Mumbai09 Dec 2024AY 2002-2003

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Ravi Sawana, Adv., Ms. Neha Sharma & Shri Apurva Chudhry, A/RFor Respondent: Shri Kailash C. Kanojiya, CIT, D/R
Section 80I

…60 to 64 in the total income of the individual; (iii) adjusting intra-head and/or inter-head losses; and (iv) setting off brought forward unabsorbed losses and unabsorbed depreciation, etc. 9. In CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd. [1997] 224 ITR 604 (SC), the respondent was a co-operative society. It carried on business in manufacture and sale of tea from bought tea leaves and the purchase and supply of agricultural manure to members. It was also receiving income from dividend from investments with other cooperative societies. In the previous year relevant to the I.T.A. No. 1387 to 1390/Mum/…

PR. COMMISSIONER OF INCOME TAX -7 vs. PRAGATI POWER CORPORATION LTD.

ITA/469/2024HC Delhi30 Aug 2024

Bench: HON'BLE MR. JUSTICE YASHWANT VARMA,HON'BLE MR. JUSTICE RAVINDER DUDEJA

Section 80Section 80A

…apter VI-A if the gross total income was “Nil”. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd: 224 ITR 605, that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter IV-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

PR. COMMISSIONER OF INCOME TAX -7 vs. PRAGATI POWER CORPORATION LTD.

ITA - 469 / 2024HC Delhi30 Aug 2024
Section 80Section 80A

…apter VI-A if the gross total income was “Nil”. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd: 224 ITR 605, that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter IV-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

Accordingly, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 1152/BANG/2023[2018-19]Status: DisposedITAT Bangalore28 Feb 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

For Appellant: Shri Padam Chand Khincha, CAFor Respondent: Shri Subramanian .S, JCIT DR
Section 10ASection 10A(9)Section 250

…ments of the Supreme Court i.e. Cambay Electric Supply [1978] 113 ITR 84 (SC), Cloth Traders [1979] 118 ITR 243 (SC), Distributor Baroda [1085] 155 ITR 120 (SC), HH Sir Ram Verma [1994] 205 ITR 433 (SC), Kotagiri Industrial Co-operative Tea Factory Ltd [1997] 224 ITR 604 (SC) concluded as under: "19) Reading of Section 80HH along with Section 80A would clearly signify' that such a deduction has to be of gross profits and gains, i.e., before computing the income as specified in Sections 30 to 43D of the Act. It is correctly pointed out by Division Bench in the reference order that in Mali/al Pesticides case, the C…

M/S. TATA ELXSI LIMITED,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

ITA 975/BANG/2023[2020-2021]Status: DisposedITAT Bangalore08 Jan 2024AY 2020-2021

Bench: Shri George George K. & Shri Chandra Poojari

Section 10ASection 30Section 80ASection 80HSection 80I

…s of the Supreme Court i.e. Bombay Electric Supply [1978] 113 ITR 59 (SC), Cloth Traders [1979] 118 ITR 845 (SC), Distributor Baroda [1985] 155 ITR 120 (SC), H.H. Sir Rama Varma [1994] 205 ITR 433 (SC), Kotagiri Industrial Co-Operative Tea Factory Ltd. [1997] 224 ITR 604 (SC) concluded as under:- "19) Reading of Section 80HH along with Section 80A would clearly signify that such a deduction has to be of gross profits and gains, i.e., before computing the income as specified in Sections 30 to 43D of the Act. It is correctly pointed out by Division Bench in the reference order that in Mal/ial Pesticides (case, the…

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 927/BANG/2023[2016-17]Status: DisposedITAT Bangalore08 Jan 2024AY 2016-17

Bench: Shri George George K. & Shri Chandra Poojari

For Appellant: Shri Padam Chand Kincha, A.RFor Respondent: Shri D.K. Mishra, D.R
Section 10ASection 30Section 80ASection 80H

…ments of the Supreme Court i.e. Cambay Electric Supply [1978] 113 ITR 84 (SC), Cloth Traders [1979] 118 ITR 243 (SC), Distributor Baroda [1085] 155 ITR 120 (SC), HH Sir Ram Verma [1994] 205 ITR 433 (SC), Kotagiri Industrial Co-operative Tea Factory Ltd [1997] 224 ITR 604 (SC) concluded as under: "19) Reading of Section 80HH along with Section 80A would clearly signify' that such a deduction has to be of gross profits and gains, i.e., before computing the income as specified in Sections 30 to 43D of the Act. It is correctly pointed out by Division Bench in the reference order that in Mali/al Pesticides case, the C…

PRAGATI POWER CORPORATION LTD.,NEW DELHI vs. ACIT, CIRCLE-20(1), NEW DELHI

ITA 1168/DEL/2018[2013-14]Status: DisposedITAT Delhi05 Jan 2024AY 2013-14

Bench: Sh. C. N. Prasaddr. B. R. R. Kumar

For Appellant: Sh. Ved Jain, Adv. &For Respondent: Sh. P. N. Barnwal, CIT-DR
Section 35Section 40Section 43BSection 80I

…Chapter VI-A if the gross total income was „Nil". It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd: 224 ITR 605, that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total income m…

M/S. VENKATESWARA HOSPITALS,,CHENNAI vs. ACIT, NCC - 2 (1),, CHENNAI

The appeal stands partly allowed in terms of our above order

ITA 2376/CHNY/2019[2017-18]Status: DisposedITAT Chennai15 Feb 2022AY 2017-18

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri Arjunraj (CA) – Ld. ARFor Respondent: Shri G. Johnson (Addl.CIT) – Ld. DR
Section 143(1)Section 80Section 80I

…T.A.No.1279/2008 dated 10.02.2010, the Court after taking into consideration the decision in the case of Synco Industries Ltd., (Supra) and the decision in the case of Commissioner Income Tax Vs. Kotagiri Industrial Co- operative Tea Factory Ltd., reported in 224 ITR 605 held as follows: “From the above extract, it is apparent that the Supreme Court did not at all hold that while computing the deduction under Section 80-I(6), the loss of one eligible industrial undertaking is to be set off against the profit of another eligible industrial undertaking. All that the Supreme Court said was that in computing the gros…

M/S PRAGATI POWER CORPORATION LTD.,,NEW DELHI vs. ACIT, NEW DELHI

In the result the appeal of the assessee is allowed for statistical purposes

ITA 2712/DEL/2017[2012-13]Status: DisposedITAT Delhi10 Jan 2020AY 2012-13

Bench: Shri Amit Shukla & Shri O.P. Kantassessment Year: 2012-13

Section 80Section 80ASection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘E’, NEW DELHI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI O.P. KANT, ACCOUNTANT MEMBER Assessment Year: 2012-13 M/s. Pragati Power Vs. ACIT, Corporation Ltd., Circle-20(1), Himadri, Rajghat Power New Delhi House Office Complex, Rajghat, New Delhi PAN :AACCP8035F (Appellant) (Respondent) Appellant by Shri Ved Jain, Adv., Ms. Umang Luthra, Adv. Shri Himanshu Aggarwal, CA Respondent by Ms. Pramita M. Biswas, CIT(DR) Date of hearing 06.01.2020 Date of pronouncement 10.01.2020 ORDER PER O.P. KANT, AM: This appeal by the assessee is directed against order…

ITO, NAMAKKAL vs. TIRUCHENGODE AGRICULTURAL PRODUCERS CO-OPERATIVE MARKETING SOCIETY LIMITED, NAMAKKAL

In the result, the Revenues’ appeals are allowed and the assessee’s COs, dismissed

ITA 363/CHNY/2017[2010-11]Status: DisposedITAT Chennai22 Sept 2017AY 2010-11

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: 02.08.2017
Section 80P(1)Section 80P(2)(a)

…(SC) (at para 3/pg.4 of the judgment). The law in the matter is well settled. Reference in this regard may also be made to decisions, inter alia, in IPCA Laboratory Ltd. v. Dy. CIT [2004] 266 ITR 521 (SC) and CIT v. Kotagiri Industrial Tea Factory Ltd. [1997] 224 ITR 604 (SC). The assessee has in fact not raised any dispute in this regard at any stage. Rather, on account of claiming deduction on gross income, i.e., without deducting expenses, its claim for deduction u/s. 80P exceeds the GTI, being at ". 410.28 lacs and ". 598.54 lacs as against the GTI at ". 209.20 lacs and ". 343.69 lacs for the two successive y…

ITO, NAMAKKAL vs. TIRUCHENGODE AGRICULTURAL PRODUCERS CO-OPERATIVE MARKETING SOCIETY LIMITED, NAMAKKAL

In the result, the Revenues’ appeals are allowed and the assessee’s COs, dismissed

ITA 362/CHNY/2017[2008-09]Status: DisposedITAT Chennai22 Sept 2017AY 2008-09

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddy

For Appellant: NoneFor Respondent: 02.08.2017
Section 80P(1)Section 80P(2)(a)

…(SC) (at para 3/pg.4 of the judgment). The law in the matter is well settled. Reference in this regard may also be made to decisions, inter alia, in IPCA Laboratory Ltd. v. Dy. CIT [2004] 266 ITR 521 (SC) and CIT v. Kotagiri Industrial Tea Factory Ltd. [1997] 224 ITR 604 (SC). The assessee has in fact not raised any dispute in this regard at any stage. Rather, on account of claiming deduction on gross income, i.e., without deducting expenses, its claim for deduction u/s. 80P exceeds the GTI, being at ". 410.28 lacs and ". 598.54 lacs as against the GTI at ". 209.20 lacs and ". 343.69 lacs for the two successive y…

SYNGENTA INDIA LTD,PUNE vs. ASST CIT RG 1(3)(1), MUMBAI

In the result, appeal of the revenue stands dismissed

ITA 147/MUM/2016[2011-12]Status: DisposedITAT Mumbai30 Nov 2016AY 2011-12

Bench: Shri R. C. Sharma & Shri Amit Shuklait(Tp)A No.: 1373/Mum/2014 (Assessment Year 2009-10) ससिंगएनता इिंडिमा प्राइवेट सरसभटेि Vs Dy. Cit- 1(3), Room No.564, Syngenta India Ltd., Aayakar Bhavan, S No. 110/11/3, Amar Paradigm M K Road, Mumbai – 400 020 Baner Road, Pune -411 045 स्थमी रेखा सिं. Pan: Aaecs 9424 P अऩीराथी (Appellant) प्रत्मथी (Respondent)

For Respondent: Shri N K Chand
Section 143(3)Section 144C(5)Section 253(1)Section 92C(2)

…income was 'nil. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT vs. Kotagiri Industrial Co-operative Tea Factory Ltd. (1997) 139 CTR (SC) 359 : (1997) 224 ITR 604 (SC), that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

SYNGENTA INDIA LTD,PUNE vs. ADDL CIT RG 1(3), MUMBAI

In the result, appeal of the revenue stands dismissed

ITA 560/MUM/2015[2010-11]Status: DisposedITAT Mumbai30 Nov 2016AY 2010-11

Bench: Shri R. C. Sharma & Shri Amit Shuklait(Tp)A No.: 1373/Mum/2014 (Assessment Year 2009-10) ससिंगएनता इिंडिमा प्राइवेट सरसभटेि Vs Dy. Cit- 1(3), Room No.564, Syngenta India Ltd., Aayakar Bhavan, S No. 110/11/3, Amar Paradigm M K Road, Mumbai – 400 020 Baner Road, Pune -411 045 स्थमी रेखा सिं. Pan: Aaecs 9424 P अऩीराथी (Appellant) प्रत्मथी (Respondent)

For Respondent: Shri N K Chand
Section 143(3)Section 144C(5)Section 253(1)Section 92C(2)

…income was 'nil. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT vs. Kotagiri Industrial Co-operative Tea Factory Ltd. (1997) 139 CTR (SC) 359 : (1997) 224 ITR 604 (SC), that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

DCIT 1(3), MUMBAI vs. SYNGENTA INDIA LTD, PUNE

In the result, appeal of the revenue stands dismissed

ITA 1926/MUM/2014[2009-10]Status: DisposedITAT Mumbai30 Nov 2016AY 2009-10

Bench: Shri R. C. Sharma & Shri Amit Shuklait(Tp)A No.: 1373/Mum/2014 (Assessment Year 2009-10) ससिंगएनता इिंडिमा प्राइवेट सरसभटेि Vs Dy. Cit- 1(3), Room No.564, Syngenta India Ltd., Aayakar Bhavan, S No. 110/11/3, Amar Paradigm M K Road, Mumbai – 400 020 Baner Road, Pune -411 045 स्थमी रेखा सिं. Pan: Aaecs 9424 P अऩीराथी (Appellant) प्रत्मथी (Respondent)

For Respondent: Shri N K Chand
Section 143(3)Section 144C(5)Section 253(1)Section 92C(2)

…income was 'nil. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT vs. Kotagiri Industrial Co-operative Tea Factory Ltd. (1997) 139 CTR (SC) 359 : (1997) 224 ITR 604 (SC), that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

SYNGENTA INDIA LTD,PUNE vs. ADDL CIT RG 1(3), MUMBAI

Accordingly, we direct the AO to allow the actual expenditure incurred during this year on site restoration cost. Accordingly, ground no. 5 is treated as allowed

ITA 649/MUM/2013[2008-09]Status: DisposedITAT Mumbai01 Jun 2016AY 2008-09

Bench: Shri B R Baskaran & Shri Amit Shukla

Section 143(3)Section 144C(5)Section 145ASection 80I

…income was 'nil. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT vs. Kotagiri Industrial Co-operative Tea Factory Ltd. (1997) 139 CTR (SC) 359 : (1997) 224 ITR 604 (SC), that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI- A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total in…

SYNGENTA INDIA LTD,PUNE vs. ADDL CIT 1(3), MUMBAI

Accordingly, we direct the AO to allow the actual expenditure incurred during this year on site restoration cost. Accordingly, ground no. 5 is treated as allowed

ITA 8534/MUM/2011[2007-08]Status: DisposedITAT Mumbai01 Jun 2016AY 2007-08

Bench: Shri B R Baskaran & Shri Amit Shukla

Section 143(3)Section 144C(5)Section 145ASection 80I

…income was 'nil. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT vs. Kotagiri Industrial Co-operative Tea Factory Ltd. (1997) 139 CTR (SC) 359 : (1997) 224 ITR 604 (SC), that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI- A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total in…

THE COMMISSIONER OF INCOME TAX vs. SONA KOYA STEERING SYSTEMS LTD.

The appeals are dismissed

ITA/761/2009HC Delhi10 Feb 2010

Bench: Us, Being The Order Dated 28.09.2007 Relating To Assessment Years 1992-93 & 1993-94 Arising Out Of Ita Nos. 2703/Del/2004, 2704/Del/2004 & The Order Dated 06.06.2008 Which Relates To Assessment Years 1994-95, 1995-96 & 2000- 01 In Ita Nos.3877/Del/2005, 3878/Del/2005 & 5480/Del/2003.

For Respondent: Mr R. Santhanam
Section 28Section 80

…er VI-A if the gross total income was „Nil‟. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd: 224 ITR 605, that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

COMMISSIONER OF INCOME TAX vs. SONO KOYO STEERING SYSTEMS LTD. GURGAON

The appeals are dismissed

ITA/1279/2008HC Delhi10 Feb 2010

Bench: Us, Being The Order Dated 28.09.2007 Relating To Assessment Years 1992-93 & 1993-94 Arising Out Of Ita Nos. 2703/Del/2004, 2704/Del/2004 & The Order Dated 06.06.2008 Which Relates To Assessment Years 1994-95, 1995-96 & 2000- 01 In Ita Nos.3877/Del/2005, 3878/Del/2005 & 5480/Del/2003.

For Respondent: Mr R. Santhanam
Section 28Section 80

…er VI-A if the gross total income was „Nil‟. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd: 224 ITR 605, that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

THE COMMISSIONER OF INCOME TAX DELHI vs. SONA KOYO STEERING SYSTEMS LTD.

The appeals are dismissed

ITA/788/2009HC Delhi10 Feb 2010

Bench: Us, Being The Order Dated 28.09.2007 Relating To Assessment Years 1992-93 & 1993-94 Arising Out Of Ita Nos. 2703/Del/2004, 2704/Del/2004 & The Order Dated 06.06.2008 Which Relates To Assessment Years 1994-95, 1995-96 & 2000- 01 In Ita Nos.3877/Del/2005, 3878/Del/2005 & 5480/Del/2003.

For Respondent: Mr R. Santhanam
Section 28Section 80

…er VI-A if the gross total income was „Nil‟. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd: 224 ITR 605, that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

THE COMMISSIONER OF INCOME TAX III vs. SONO KOYO STEERING SYSTEMS LTD. GURGAON

The appeals are dismissed

ITA - 194 / 2009HC Delhi10 Feb 2010

Bench: Us, Being The Order Dated 28.09.2007 Relating To Assessment Years 1992-93 & 1993-94 Arising Out Of Ita Nos. 2703/Del/2004, 2704/Del/2004 & The Order Dated 06.06.2008 Which Relates To Assessment Years 1994-95, 1995-96 & 2000- 01 In Ita Nos.3877/Del/2005, 3878/Del/2005 & 5480/Del/2003.

For Respondent: Mr R. Santhanam
Section 28Section 80

…er VI-A if the gross total income was „Nil‟. It is in that context that the Supreme Court considered the concept of gross total income and came to the conclusion, following its earlier decision in CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd: 224 ITR 605, that the gross total income has to be computed in accordance with the Act after adjusting the losses, etc. and that, if the gross total income so determined is positive, then the question of allowing deductions under Chapter VI-A would arise, but not otherwise. While doing so, the Supreme Court further made it clear that the gross total inc…

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CIT v. Kotagiri Industrial Co-operative Tea Factory Ltd. (224 ITR 605) — Cited in 25 Judgments | BharatTax