1965 (12) TMI 34 - SUPREME COURT

Whether the source of the amounts was the production or the export of the rubber itself by the owners of the plantations and as the amount was paid back to the producers it was only a trading receipt?

Held that:- The amounts from the fund earmarked for the appellants on the basis of the rubber produced by them were paid against the expenditure incurred by them for maintaining the rubber plantation and producing the rubber. If so, it follows that the receipts by the assessees during the accounting year were revenue receipts and, therefore, liable to be included in their assessable income. We therefore hold, though for different reasons, that the High Court has rightly answered the questions against the assessees. The appeals fail, and are dismissed with costs.