JUDGMENT

Santosh Hegde, J.-The income from cultivation, manufacture and sale of tea being a composite income is exigible to both income-tax under the Indian Income Tax Act, 1961 and the Assam Agricultural Income Tax Act, 1939.

2. In this context, being aggrieved by the decision of the Agricultural Income Tax Officer of the State of Assam (State Officer) who refused to accept the computation of agricultural income made by the Income Tax Officer (Central Officer) under the Income Tax Act, 1961 (Central Act) for the purpose of the levy of Assam agricultural income tax for the relevant assessment years, assessees-appellants approached the High Court of Guwahati by way of writ petitions questioning the authority of the State Officer to recompute the agricultural income already assessed by the Central Officers under the Central Act and for consequential reliefs. Their contentions being rejected both by the learned Single Judge and the Division Bench of High Court of Guwahati, these appeals/petitions have been preferred.

3. It was argued on behalf of the appellants before the High Court that in view of the constitutional definition of agricultural income under Article 366(1) of the Consti