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Microlesson · 5-min read

Composite Income — Business and Agricultural Income (Rules 7A, 7B, 8) and Replantation Allowance

# Composite Income — Splitting Business and Agricultural Income

Where a product is both grown (agricultural activity) and manufactured/processed (business activity) by the same person, the income is composite. Specific Income-tax Rules apportion it between exempt agricultural income and taxable business income.

## The apportionment rules

RuleIncome sourceAgricultural % (exempt)Business % (taxable)
7ASale of rubber products from rubber plants grown by the seller in India65%35%
7BSale of coffee grown and cured by the seller in India75%25%
7BSale of coffee grown, cured, roasted and grounded by the seller in India60%40%
8Sale of tea grown and manufactured by the seller in India60%40%

> Only the business percentage is taxed under the head PGBP; the agricultural percentage is exempt u/s 10(1) (but counts for rate-purposes / partial integration).

## Allowance for replantation costs

  • A deduction is allowed for the cost of replanting bushes/plants (tea bushes, rubber plants, coffee plants) that have died or become permanently useless, within an area already planted.
  • No deduction is allowed where a subsidy for replantation/replacement is received that is exempt under Section 10(30) or Section 10(31) (you cannot claim a cost that was funded by exempt subsidy).

## Subsidy exemptions

  • Section 10(30): exempts subsidies from the Tea Board for replantation, replacement, rejuvenation or consolidation of tea areas.
  • Section 10(31): exempts subsidies from the respective boards for replantation, replacement, rejuvenation or consolidation of areas for rubber, coffee, cardamom or other notified commodities.

Worked example

### Example 1

Tea (Rule 8). A tea grower-manufacturer earns composite income of ₹20,00,000. Business income = 40% × ₹20,00,000 = ₹8,00,000 (taxable under PGBP); agricultural income = 60% × ₹20,00,000 = ₹12,00,000 (exempt, but considered for partial integration).

### Example 2

Coffee (Rule 7B). A seller grows, cures, roasts and grinds coffee, earning composite income of ₹10,00,000. Business portion = 40% = ₹4,00,000; agricultural portion = 60% = ₹6,00,000. (Had the coffee only been grown and cured, the split would be 25% / 75%.)

### Example 3

Replantation with subsidy. A rubber estate spends ₹3,00,000 replanting dead plants and receives a ₹1,20,000 subsidy from the Rubber Board (exempt u/s 10(31)). Only the cost not funded by the exempt subsidy is deductible — ₹3,00,000 − ₹1,20,000 = ₹1,80,000.

⚠️ Common exam mistakes

  • Mixing up the two coffee rates — 'grown and cured' is 25% business, while 'grown, cured, roasted and grounded' is 40% business.
  • Taxing the agricultural portion — it is exempt (though used for partial integration / rate purposes).
  • Claiming replantation cost in full when an exempt subsidy u/s 10(30)/10(31) was received to fund it.
  • Confusing rubber (Rule 7A, 35% business) with tea (Rule 8, 40% business).
Bare-Act text Rules 7A, 7B and 8 (read with Sections 10(30) and 10(31)) · Income-tax Rules, 1962 · click to expand
Rule 7A: Income from the manufacture of rubber — 35% of such income is taxable as business income (65% treated as agricultural income). Rule 7B: Income from the sale of coffee grown and cured by the seller — 25% taxable as business income (75% agricultural); coffee grown, cured, roasted and grounded — 40% taxable (60% agricultural). Rule 8: Income from the manufacture of tea — 40% taxable as business income, 60% treated as agricultural income.
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