Implementing assessment orders are beyond revision, and bonus paid in the relevant year remains deductible despite earlier accounting references.

A revisional authority cannot disturb an assessment order that was passed solely to implement binding Tribunal directions, and a limitation challenge fails where the revision is directed at that implementing order rather than the earlier assessment. The text also states that bonus paid in the relevant previous year is deductible under section 8(9) if it is revenue expenditure incurred wholly and exclusively for earning agricultural income, even when the bonus relates to earlier accounting years. On this reasoning, the revisional disallowance is said to be erroneous and the assessee's deduction claim is upheld.

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Issues: (i) Whether the Deputy Commissioner had jurisdiction to revise the Agricultural Income-tax Officer's order made in implementation of the Tribunal's directions and whether the revision was barred by limitation; (ii) whether bonus paid during the relevant previous year was allowable as a deduction under section 8(9) though it related to earlier accounting years.

Issue (i): Whether the Deputy Commissioner had jurisdiction to revise the Agricultural Income-tax Officer's order made in implementation of the Tribunal's directions and whether the revision was barred by limitation.

Analysis: The Tribunal had not merely remanded the matter for a fresh assessment at large; it had set aside the earlier view on the relevant previous year, directed reassessment in the light of its findings, and required recalculation of income and deductions. The order dated 31 October 1974 was therefore an implementing order passed to give effect to the Tribunal's decision. An order so passed was not open to revision by the Commissioner or Deputy Commissioner under the revisional power against subordinate authority orders. The challenge based on limitation also failed because the impugned revision was directed against the 1974 order and not against the earlier 1968 assessment order.

Conclusion: The revision was without jurisdiction and the limitation objection did not sustain the impugned revisional order.

Issue (ii): Whether bonus paid during the relevant previous year was allowable as a deduction under section 8(9) though it related to earlier accounting years.

Analysis: Section 8(9) permits deduction of expenditure incurred wholly and exclusively for the purpose of deriving agricultural income, provided it is not capital or personal expenditure and is incurred in the relevant previous year. The statutory language does not require the expenditure to relate only to income of that very year. The payment of bonus during the relevant previous year was sufficient, and the earlier accounting years to which the bonus calculations related did not disqualify the deduction. A contrary construction would defeat the allowance of bona fide revenue expenditure and produce an unjust result inconsistent with the scheme of the Act.

Conclusion: The bonus was allowable as a deduction and the revisional disallowance was erroneous.

Final Conclusion: The revisional orders were quashed, the assessee's deduction claim was upheld, and the writ petition succeeded with costs.

Ratio Decidendi: A revisional authority cannot interfere with an assessment order made merely to implement binding appellate directions, and revenue expenditure incurred in the relevant previous year is deductible under section 8(9) without any further requirement that it must relate to the income of that same year.

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