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Costing and Taxation · Ch 6 — Agricultural Income

Taxability of Composite Income from Tea and Coffee Grown and Manufactured in India

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Taxability of Composite Income from Tea and Coffee Grown and Manufactured in India

Growing tea or coffee is agriculture; roasting, curing, or otherwise processing it into a marketable product goes beyond what Section 2(1A)'s limb (b) treats as an ordinary agricultural process. A business that BOTH grows AND manufactures its own tea or coffee is therefore a composite business, mixing a genuinely agricultural activity with a genuinely business (manufacturing) activity in one integrated operation. The Income-tax Rules, 1962 fix an exact percentage split for exactly this situation, so that the agricultural portion can be kept exempt and the business portion taxed.

Tea — Rule 8

Note

Rule 8 — Income from the manufacture of tea grown and manufactured in India

Where income is derived from the sale of tea grown and manufactured by the seller in India, 60% of that income is treated as agricultural income (exempt), and the remaining 40% is treated as business income (taxable).

Coffee — Rule 7B

Coffee has TWO different splits, depending on how much processing the seller carries out:

Note

Rule 7B(1) — Coffee grown and cured only

Where the seller grows coffee and cures it (but does not roast or grind it) in India, 25% of the income is treated as business income (taxable), and 75% is treated as agricultural income (exempt).

Note

Rule 7B(1A) — Coffee grown, cured, roasted and grounded

Where the seller grows, cures, roasts AND grinds coffee in India — with or without mixing chicory or other flavouring ingredients — 40% of the income is treated as business income (taxable), and 60% is treated as agricultural income (exempt).

Why the business share rises with the level of processing

ActivityBusiness income (taxable)Agricultural income (exempt)Rule
Tea — grown and manufactured40%60%Rule 8
Coffee — grown and cured only25%75%Rule 7B(1)
Coffee — grown, cured, roasted and ground (with/without chicory)40%60%Rule 7B(1A)

The more processing a seller carries out beyond the basic cultivation-and-curing stage — roasting and grinding, in coffee's case — the larger the share of value added by a genuinely business-like (manufacturing) activity, and correspondingly the larger the percentage the Rules treat as taxable business income.

Beyond tea and coffee: the general principle (a brief, honest note)

Note

Scope note …