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2012 (5) TMI 276 - HC - Income TaxAgricultural income Vs. Business income - Sale of palm oil - activity of extracting crude palm oil from palm pericarp (fruit portion excluding the kernel) and also from the kernel - Rule 7 of the Income-tax Rules, 1961 - mechanical and other process - held that:- activity carried out by the appellant in the extraction of oil from the fruit/ from the kernel is an industrial activity and, therefore, income from such activity is assessable as its "profits and gains of business" under Section 28 of the Income Tax Act. - Decided against the assessee. Double taxation - payment of state tax on agriculture income and central income tax - held that:- eligible relief can be considered only in the writ petition pending and not in these statutory appeals filed by the appellant under Section 260A of the Income Tax Act wherein we have considered the substantial question of law arising from the orders of the Tribunal.
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