TMI Blog1993 (3) TMI 32X X X X Extracts X X X X X X X X Extracts X X X X ..... .-This income-tax reference pertains to the assessment years 1962-63, 1963-64 and 1965-66. The following questions are before us for consideration under section 256(2) of the Income-tax Act, 1961 : "1. Whether, on the facts and in the circumstances of the case, the expenses of running the railway lines should be allocated between the agricultural operations and the non-agricultural operations on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ceipts amounting to Rs. 20,788 being freight receipts were fully assessable as income from manufacturing business of the assessee ? " Assessment year 1965-66 : "Whether, on the facts and in the circumstances of the case, the railway transport receipts amounting to Rs. 15,075 being freight receipts were fully assessable as income from manufacturing business of the assessee ?" As far as questi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nes as between agricultural and manufacturing activities of the assessee-company should also be done on the "ton mileage" basis as set out in the above judgment. In view of the above, question No. 2 is answered in the negative and in favour of the assessee. Regarding the questions raised for the assessment year 1962-63 as also for the assessment year 1965-66, the only facts which are before us ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1965-66, the assessee claimed that, out of the receipts so obtained amounting to Rs. 54,134, the sum of Rs. 31,522 exclusively related to the manufacturing activity of the company. Of the balance of Rs. 22,612, one-third thereof, viz., Rs. 7,537, related to manufacturing activities and the balance of Rs. 15,075 related to agricultural activity, The Tribunal has held that the balance amount of R ..... X X X X Extracts X X X X X X X X Extracts X X X X
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