Separate legal entities cannot have agricultural holdings clubbed for assessment absent express statutory authority.

Under the Tamil Nadu Agricultural Income-tax Act, 1955, agricultural holdings belonging to distinct legal persons cannot be clubbed for assessment unless the statute expressly authorises aggregation. Section 3(1) taxes the total agricultural income of every person, but the definitions of "person" and "to hold" in Section 2(q) and Section 2(nn) support separate treatment where the trustee under one deed and the school under another are different legal entities. On that basis, the authorities had no jurisdiction to treat the two extents as one holding, and the clubbing for assessment was unsustainable.

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Issues: Whether the agricultural lands held under two different deeds could be clubbed for assessment under the Tamil Nadu Agricultural Income-tax Act, 1955, and whether such clubbing was without jurisdiction.

Analysis: Section 3(1) of the Act charges agricultural income-tax on the total agricultural income of every person, while the definitions of "person" and "to hold" in Section 2(q) and Section 2(nn) indicate that holdings may belong to different persons. Where the trustee under the earlier deed and the school under the later deed are distinct legal entities, the statutory basis for treating their holdings as one does not exist. The separate legal status of the petitioner-school from the trustee prevents the authorities from aggregating the two extents for assessment.

Conclusion: The clubbing of the two extents was without jurisdiction and was unsustainable; the writ petitions were rightly allowed in favour of the petitioner.

Ratio Decidendi: Under the Tamil Nadu Agricultural Income-tax Act, 1955, holdings belonging to distinct legal persons cannot be clubbed for assessment unless the statute expressly authorises such aggregation.

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