Weighted deduction under section 35C denied for insecticide spray and road works where statutory conditions were not met.

Weighted deduction under section 35C was confined to expenditure that met the statutory conditions, including direct incurrence and compliance with prescribed approval requirements. Aerial spray expenses incurred through the Cane Development Council did not qualify because the Council was not an approved association or body for section 35C purposes, so the allowance was denied. Road-repair expenses and contributions for construction of a new road also failed to satisfy the conditions under section 35C read with rule 6A, and were likewise disallowed. Both referred questions were answered against the assessee and in favour of the Revenue.

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Issues: (i) Whether the assessee was entitled to weighted deduction under section 35C of the Income-tax Act, 1961, in respect of expenditure on aerial spray of insecticides; (ii) Whether the assessee was entitled to weighted deduction under section 35C read with rule 6A in respect of road-repair expenses and contribution for construction of a new road.

Issue (i): Whether the assessee was entitled to weighted deduction under section 35C of the Income-tax Act, 1961, in respect of expenditure on aerial spray of insecticides.

Analysis: The expenditure was incurred through the Cane Development Council on behalf of the assessee and others. The Council was not an association or body approved by the prescribed authority for the purpose of section 35C, and the statutory allowance was available only where the expenditure was directly incurred in the manner contemplated by the provision.

Conclusion: The assessee was not entitled to weighted deduction on this amount and the answer was in favour of the Revenue.

Issue (ii): Whether the assessee was entitled to weighted deduction under section 35C read with rule 6A in respect of road-repair expenses and contribution for construction of a new road.

Analysis: The expenditures claimed were not shown to satisfy the prescribed conditions for weighted deduction under section 35C read with rule 6A, and therefore did not qualify for the allowance claimed.

Conclusion: The assessee was not entitled to weighted deduction on these expenditures and the answer was in favour of the Revenue.

Final Conclusion: Both referred questions were answered against the assessee, and the reference was disposed of accordingly.

Ratio Decidendi: Weighted deduction under section 35C is allowable only when the expenditure satisfies the statutory conditions, including direct incurrence or other prescribed requirements, and absence of approved-authority compliance defeats the claim.

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