STATE OF ASSAM vs M/S.ASSAM FRONTIER TEA LTD — C.A. No. 7863/1997

Case Summary: State of Assam v. M/s. Assam Frontier Tea Ltd. (C.A. 7863/1997) Outcome: The Supreme Court allowed the State of Assam's appeal, set aside the High Court's judgment, and restored the Single Judge's order dismissing the assessee's writ petition. The respondent was ordered to pay costs of Rs. 25,000. Key Issue: Whether Assam Frontier Tea Ltd. could claim a Rs. 4 crore deduction for "workmen and staff welfare" (paid to sister concerns) as agricultural income under the Assam Agricultural Income Tax Act, 1939. The Court found the assessee failed to provide factual material demonstrating the expenditure was laid out "wholly and exclusively" for earning agricultural income, as statutorily required, and rejected the argument that prior High Court precedent (George Williamson case) precluded the State from challenging the decision. This case analysis is maintained by casestatus.in based on publicly available court records.