Judgement

BACHAWAT, J. :- The appellant carry on the business of cultivation, manufacture and sale of tea. They own tea plantations in the State of Kerala. Some of them own tea plantations both within and outside the State. They are assessed to non-agricultural as well as agricultural incometax. Civil Appeals Nos. 936 to 939 of 1966 arise out of the agricultural income-tax assessments of the Anglo American Direct Tea Trading Co., Ltd. under the Kerala Agricultural Income-tax Act, 1950 for the years 1958-59. 1959-60, 1960-61 and l961-62. Civil Appeals Nos. 585 to 588 of 1966 arise out of the agricultural income-tax assessments of the Travancore Tea Estates Co. Ltd. for the years 1957-58, 1958-59, 1959-60 and 1960-61. Civil Appeals Nos. 589 to 591 of 1966 arise out of the agricultural income-tax assessments of the Southern India Tea Estates Co. Ltd., for the years 1957-58, 1958-59 and 1959-60. For all the assessment years, the central income-tax authorities computed the total tea income of the appellants and 40 per cent thereof representing the non-agricultural income was assessed to non-agricultural income-tax and the balance 60 per cent was left unassessed as agricultural income. Th