M/S. Assam Company Ltd. & Anr vs State Of Assam & Ors

The Supreme Court ruled that the income from tea cultivation, manufacture, and sale is subject to taxation under both the Indian Income Tax Act, 1961 and the Assam Agricultural Income Tax Act, 1939. The Court upheld the High Court's decision that State Officers have the authority to recompute agricultural income assessed by Central Officers, provided the recomputation is justified under the Central Act. The Court clarified that such provisions are not ultra vires the Constitution and are consistent with Article 246(3) and Article 366(1).