Commissioner Of Income Tax vs Willamson Financial Services & Ors

The Supreme Court addressed the applicability of Section 80HHC of the Income-tax Act, 1961, determining that the deduction should be allowed against the entire composite income from tea before the 60:40 apportionment under Rule 8(1) of the Income-tax Rules, 1962. The Court held that the computation of income must consider all permissible deductions under the Act, including those under Chapter VIA, such as Section 80HHC. The judgment reversed the Tribunal's decision, favoring the assessees' claim for the deduction prior to apportionment.