Special deduction ceiling for agricultural interest expense cannot be bypassed by invoking the general deduction clause.

Section 5(k) was treated as the special provision governing interest expenditure connected with agricultural income, and its embedded ceiling could not be bypassed by recasting the claim under section 5(e). Interest on borrowings made in earlier years remained within section 5(k) if it related to the specified purpose, so the year of borrowing did not take the amount outside that provision. The disallowance based on the statutory limit therefore could not be enlarged in later years through the general deduction clause, and the challenge to the disallowance failed.

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Issues: Whether interest expenditure relating to agricultural income could be claimed beyond the limit prescribed under section 5(k) by resorting to section 5(e), and whether interest on borrowings made in earlier years for the relevant purpose was outside section 5(k).

Analysis: Section 5(k) was treated as the special provision governing interest on borrowings for the specified purpose. Interest falling within that provision could not be shifted to section 5(e) to obtain a larger deduction. The provision did not require that the borrowing itself, or the expenditure from it, must have occurred in the previous year; interest on borrowings made in earlier years remained governed by section 5(k). The amount disallowed because of the ceiling under section 5(k) could not be enlarged in later years by invoking section 5(e).

Conclusion: The claim for a larger deduction was rejected, and the assessee's challenge to the disallowance failed.

Ratio Decidendi: Where a statute contains a special deduction provision with an embedded ceiling, amounts falling within that special provision cannot be recast under a general deduction clause to bypass the statutory limit, and the provision applies to interest on qualifying borrowings irrespective of the year in which the borrowing was made.

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