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Issues: Tax revision under the Tamil Nadu Agricultural Income-tax Act, 1955 challenging disallowance of deductions for car maintenance expenses, rubber replanting subsidy, and maintenance of Bharat Medical Centre.
Car Maintenance Expenses: The Tribunal allowed 75% of the expenses but disallowed the remaining 25%. The court found no infirmity in this decision as there was insufficient evidence to justify the total deduction. The petitioner failed to provide material like the log book to prove the expenses were solely for agricultural purposes or land-related activities. Thus, the plea for further deduction was rejected. Maintenance of Bharat Medical Centre: The Tribunal rejected the claim due to lack of evidence on the center's constitution and its exclusivity for company workers. A previous Division Bench decision allowed 50% deduction for a similar claim, stating that unless it's proven that agricultural workers do not use the facilities, the claim cannot be entirely rejected. Following this principle, the court allowed 50% deduction for the maintenance of the medical center, while the rest of the claim was rejected. Rubber Replanting Subsidy: Referring to a Division Bench decision, the court held that subsidies under the Replanting Subsidy Scheme are not taxable as revenue receipts. Following this precedent, the claim for the subsidy received from the Rubber Board was allowed in full. Conclusion: The tax revision was allowed for the rubber replanting subsidy and 50% of the deduction for the maintenance of Bharat Medical Centre. However, the claim for car maintenance expenses was dismissed due to lack of evidence supporting the full deduction. No costs were awarded in this matter.
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