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TMI Blog1992 (7) TMI 10X X X X Extracts X X X X X X X X Extracts X X X X ..... n is filed against the orders of the Agricultural Income-tax Appellate Tribunal, Madras, disallowing two items claimed by the petitioner as allowable deductions under the Tamil Nadu Agricultural Income-tax Act, 1955 ("T.N.A.I.T.", in short). The petitioner claims deduction of Rs. 2,400 and Rs. 2,056 under the head "Labour welfare expenses" in respect of payments made for conducting dramas and anot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ioning the two items disallowed by the Tribunal. With regard to the interest paid on the amounts borrowed for maintaining immature coffee plants, a Division Bench of this court in the case of the very same assessee, had held that it is an allowable deduction under section 5(e) of the Tamil Nadu Agricultural Income-tax Act, 1955, and the case is reported in Puthutotam Estates (1943) Ltd. v. State ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... indirect and remote. In our view, the conclusion reached by the Tribunal is unassailable. Mr. Srinivasamoorthy, learned counsel for the petitioner/ assessee relied upon the decision of the apex court in Sassoon J. David and Co. Pvt. Ltd. v. CIT [1979] 118 ITR 261, with regard to the construction of the expression "wholly and exclusively" used in section 10(2)(xv) of the Indian Income-tax Act, 192 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ers a wide range of expenses taking in not only the expenses incurred actually for deriving agricultural income, but also expenses which are not directly incurred for deriving agricultural income but expended in connection with the lands which do not have any relationship to the agricultural income derived in the previous year. " If the above principle is borne in mind, we have no hesitation to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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