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)
Hanuman Plantations Ltd. v. ITO (2023)104 ITR 78 (Kol) (Trib)
S. 28(i) : Business income-Agricultural income-Apportionment AO is directed to recompute disallowance and only 40% amount to be added to business income. [S. 2(24)(x), 36(1))(v),R. 8(1)]
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