Assessee engaged in the business of growing and manufacturing tea. As per Rule 8, income of the assessee is to be apportioned in the ratio 60:40 whereby 60% is treated as agricultural income and 40% is treated as business income. In light of the judgment of Hon’ble SC in the case of Checkmate Service P. Ltd. v. CIT [2022] 448 ITR 518 (SC), deduction allowable only on actual payment made within due date under respective Act. On appeal, it was held that disallowance of EPF has to be first added before computing 60:40. Thereby, only 40% of amount to be added in business income. (AY.  2019-20)