1998 (11) TMI 73

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..... ncome-tax and Sales Tax Appellate Tribunal referred the following question for the opinion of this court : "Whether, on the facts and circumstances of the case, the Tribunal was justified in confirming the disallowance of the claim for deduction of proportionate head office expenses amounting to Rs. 61,210 ?" The assessee-a public limited company-having its head office at Bombay and various es .....

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..... roduce any evidence to show that the items of expenditure are really incidental to the earning of agricultural income in the State of Kerala and that the assessee also did not prove by any cogent evidence the linkage of such expenses with the earning of agricultural income in Kerala. The first appellate authority, affirming the disallowance, held as under : "No evidences have been adduced befo .....

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..... ure to any of the functions described above are not seen furnished by the appellant-company at any stage of assessment or appeal. The appellant-company has not done that before us also. Instead, the appellant is pleading before us for a blanket acceptance of eligibility for deduction for the nomenclature 'head office expenses'. This is not sufficient for our interference on the point. In the circu .....

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