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1984 (2) TMI 9

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..... Commissioner of Agricultural Income-tax, Karnataka, Bangalore, under section 35 of the Karnataka Agricultural Income-tax Act, 1957. The Commissioner by the said order has found fault with the assessment order in relation to the following three deductions allowed : (1) consultant's fee Rs. 24,000, (2) general charges Rs. 7,418.44 and (3) auditor's fee Rs. 1,800. So far as the first item is con .....

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..... l income wholly and exclusively. He has also observed that there are no particulars of the advice received from the consultants. Of course, it is for the assessee to show that the payment made to the consultants was for the purpose of deriving agricultural income. But, to infer that the fee paid for obtaining advice in respect of a coffee estate would always be in the nature of capital expenditure .....

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..... of the Commissioner are too general and without regard to the assessment order. It is not as if the assessing officer has allowed the general charges as claimed by the assessee. He has looked into the particulars of the expenditure claimed and allowed only such of those expenses that are evidenced by vouchers. There is, therefore, no reason to consider that matter. Equally, is the observation of .....

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