Commnr. Of Income Tax, Nagpur vs Baba Saheb Kedar G.&P. Coop.Society Ltd

The Supreme Court ruled that the income derived by the assessee from ginning and pressing activities, along with storage facilities, constitutes a composite charge under the Agreement with the Federation, and the Department's ad-hoc attribution of fifty percent as rental income was unjustified. The Court emphasized the need for a detailed examination of the income sources and proportionality principles rather than applying a blanket rule. The judgment clarifies that the Department must assess the total income and allocate rental income appropriately, rejecting the simplistic fifty percent rule.