TaxSaral
Rule 271Agricultural Incomewas Rules 7A / 7B / 8 in IT Act 1961

Rule 271 — Fixed Splits for Tea, Coffee & Rubber

For Tea, Coffee, and Rubber — crops where growing and manufacturing are inseparably intertwined — the law prescribes fixed statutory percentage splits instead of requiring individual FMV calculations. This removes the need to determine a 'farm gate price' for these complex crops.

Who this applies to

Tea, coffee, and rubber plantation owners and manufacturers who grow and process their own crop.

Key Points

  • Tea (grown and manufactured): 60% of income is agricultural (exempt), 40% is business income (taxable).
  • Coffee (grown and cured only): 75% agricultural, 25% business.
  • Coffee (grown, cured, roasted AND grounded): 60% agricultural, 40% business — the extra processing shifts 15% from exempt to taxable.
  • Rubber (growing and manufacturing): 65% agricultural, 35% business.

Worked Examples

1

Tea estate — 60/40 split

Scenario

A tea estate in Assam earns ₹1,00,00,000 (₹1 crore) in total income from growing and manufacturing tea bags. What portion is taxable?

Calculation

Total income: ₹1,00,00,000

Rule 271 split for Tea (grown & manufactured):
  Agricultural income (60%): ₹60,00,000 → Exempt
  Business income (40%):     ₹40,00,000 → Taxable PGBP

Tax on ₹40L business income (default regime):
  ₹0–4L:    Nil
  ₹4L–8L:   5%  = ₹20,000
  ₹8L–12L:  10% = ₹40,000
  ₹12L–16L: 15% = ₹60,000
  ₹16L–20L: 20% = ₹80,000
  ₹20L–24L: 25% = ₹1,00,000
  ₹24L–40L: 30% = ₹4,80,000
  Total tax: ₹7,80,000 + 4% cess = ₹8,11,200

(Plus partial integration if there is other non-agri income)

Result

The estate pays tax on ₹40L (40% of revenue) — ₹60L is permanently exempt. No FMV calculations are needed; the 60/40 rule is applied mechanically to the total income.

2

Coffee — curing vs. roasting makes a difference

Scenario

A Karnataka coffee grower earns ₹50L. Compare: (A) selling cured coffee beans vs. (B) selling roasted and ground coffee.

Calculation

Option A — Grown and Cured only:
  Agricultural (75%): ₹37,50,000 → Exempt
  Business (25%):     ₹12,50,000 → Taxable

Option B — Grown, Cured, Roasted & Grounded:
  Agricultural (60%): ₹30,00,000 → Exempt
  Business (40%):     ₹20,00,000 → Taxable

Extra processing (roasting + grinding) shifts:
  Additional taxable income: ₹20L – ₹12.5L = ₹7,50,000
  Additional tax (approx.): ₹7.5L × 20% = ₹1,50,000

Result

Adding a roasting and grinding unit increases taxable business income by ₹7.5L — the extra processing reduces the agricultural exemption from 75% to 60%. The decision to add a roastery has a direct, quantifiable tax cost that must be weighed against the higher sale price of finished coffee.

Related Sections

Still have questions about Rule 271?

Our tax team can explain how this provision applies to your specific situation.

Section references are based on the Income Tax Act 2025 (Tax Year 2026-27). Examples are illustrative — verify with a Chartered Accountant before filing.