Launch offer — 25% off with code LAUNCH-25 See plans →
Microlesson · 5-min read

Apportionment between Business Income and Agricultural Income (Rules 7, 7A, 7B, 8)

# Apportionment of Composite Income — Rules 7, 7A, 7B, and 8

Where an assessee carries on a business in which agricultural produce is used as raw material for manufacture, the income has both an agricultural and a business component. The Income-tax Rules prescribe the basis of apportionment.

## Rule 7 — General Rule (Non-Specified Produce)

Applies to any agricultural produce (other than tea, coffee, rubber) used as raw material in a business.

Computation of Business Income:

ParticularsAmount
Sale Proceeds of non-agricultural (manufactured) producexxx
Less: Market value of agricultural produce (raw material) used(xxx)
Less: Manufacturing expenses(xxx)
Business Income (Taxable)xxx

The market value of the agricultural produce is treated as agricultural income (exempt).

## Rule 7A — Income from Manufacture of Rubber

  • Agricultural Income: 65% (Exempt)
  • Business Income: 35% (Taxable)

## Rule 7B — Income from Manufacture of Coffee

ActivityAgriculturalBusiness (Taxable)
Coffee grown and cured by seller75%25%
Coffee grown, cured, roasted and grounded by seller (with or without mixing chicory/flavoring agents)60%40%

## Rule 8 — Income from Manufacture of Tea

  • Agricultural Income: 60% (Exempt)
  • Business Income: 40% (Taxable)

## Summary Table

RuleProduceAgricultural (Exempt)Business (Taxable)
7Other produceMarket value of raw materialBalance
7ARubber65%35%
7B(1)Coffee — grown & cured75%25%
7B(1A)Coffee — grown, cured, roasted, grounded60%40%
8Tea60%40%

## Key Points

  • These rules apply when the assessee both grows AND manufactures the produce.
  • If the assessee only purchases the agricultural raw material (e.g., buys tea leaves and manufactures tea), the entire income is business income — no agricultural component.
  • The exempt agricultural portion is added to Total Income for rate purposes under partial integration (if applicable).

## Additional Note

Agricultural income may also be derived from any farm building required for agricultural operations (subject to conditions on location and use under Section 2(1A)(c)).

Worked example

### Example 1

Q. A tea company (grows and manufactures tea) earns a composite income of ₹10,00,000 from the sale of manufactured tea.

A. Apply Rule 8:

  • Agricultural Income (exempt) = 60% × ₹10,00,000 = ₹6,00,000
  • Business Income (taxable under PGBP) = 40% × ₹10,00,000 = ₹4,00,000

### Example 2

Q. A rubber estate (grows latex and manufactures rubber) earns composite income of ₹20,00,000.

A. Apply Rule 7A:

  • Agricultural Income (exempt) = 65% × ₹20,00,000 = ₹13,00,000
  • Business Income (taxable) = 35% × ₹20,00,000 = ₹7,00,000

### Example 3

Q. A coffee estate grows, cures, roasts and grinds its own coffee (without mixing chicory). Composite income = ₹15,00,000.

A. Apply Rule 7B(1A):

  • Agricultural Income (exempt) = 60% × ₹15,00,000 = ₹9,00,000
  • Business Income (taxable) = 40% × ₹15,00,000 = ₹6,00,000

⚠️ Common exam mistakes

  • Applying Rule 7A/7B/8 when the assessee only manufactures (does not grow) the produce — in that case, 100% is business income.
  • Swapping the percentages — remember: Tea 60/40, Rubber 65/35, Coffee (cured only) 75/25, Coffee (cured + roasted/ground) 60/40.
  • Forgetting that the exempt agricultural portion still counts for the partial integration computation (rate purposes).
  • Under Rule 7, deducting the COST of the raw material instead of its MARKET VALUE — the rule mandates market value.
  • Treating coffee 'cured AND roasted/grounded' under the 75/25 ratio — that ratio only applies to coffee grown and cured (without roasting/grinding).
Bare-Act text Rules 7, 7A, 7B and 8 of the Income-tax Rules, 1962 · Income-tax Rules, 1962 · click to expand
Rule 7: In the case of income which is partially agricultural income and partially income chargeable to tax under the head 'Profits and gains of business', the market value of the agricultural produce raised by the assessee shall be deducted, and no further deduction shall be made in respect of any expenditure incurred by the assessee as a cultivator. Rule 7A: Income derived from the sale of centrifuged latex or cenex or latex based crepes manufactured from rubber plants grown by the seller in India shall be computed as if it were income derived from business — 35% shall be deemed business income. Rule 7B: Income from sale of coffee grown and cured — 25% business income; if grown, cured, roasted and grounded — 40% business income. Rule 8: Income derived from the sale of tea grown and manufactured by the seller in India — 40% shall be deemed business income.
Now that you've read this — what's next?
Move from understanding → mastery in 3 clicks. Each option below picks up from this lesson's topic.
Start 15-min diagnostic