STATE OF TAMIL NADU vs KANNAN DEVAN MILLS PRODUCE CO. LTD.

The Supreme Court upheld the High Court's decision to quash the reopening of the assessment for the year 1960-61 under the Madras Agricultural Income-tax Act. The Court ruled that Rules 7 and 8 of the Act do not apply as the tea was manufactured in Kerala, not Madras, and emphasized that the entire estate must be assessed as a whole. The Court directed the Agricultural Income-tax Officer to accept the computation of the Central Income-tax Officer as the proper basis for assessment, given the lack of satisfactory reasons from the officer for rejecting it.