Previous year for agricultural income-tax must follow the statutory March-ending rule where no accounts are maintained.

Section 2(o) of the Agricultural Income-tax Act treats the previous year as the twelve months ending on 31 March unless the assessee has accounts made up to another date within that period and validly adopts that alternative basis. Where no accounts are maintained, the statutory condition for using a different previous year is absent. A prior Malayalam-year assessment of a different assessee, including a joint family, cannot extend that basis to an assessee who kept no accounts. The assessee was therefore not entitled to compute the previous year on the Malayalam era basis, and the Tribunal's contrary view was wrong.

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Issues: Whether an assessee who maintained no accounts could reckon any previous year other than the twelve months ending on 31 March for agricultural income-tax assessment, and whether the Tribunal could rely on the prior assessment basis of a different assessee to answer that question.

Analysis: Section 2(o) of the Agricultural Income-tax Act, 1950 defines "previous year" primarily as the twelve months ending on 31 March preceding the assessment year. The alternative of adopting a different year applies only where the assessee has accounts made up to a date within the relevant twelve months and exercises the statutory option in the manner permitted by the definition. Since the assessee had no accounts at all, the statutory condition for invoking the alternative basis was absent. The fact that the joint family had earlier been assessed on a Malayalam year basis could not extend that method to the assessee in the absence of accounts maintained by him.

Conclusion: The assessee was not entitled to reckon the previous year by the Malayalam era, and the Tribunal's contrary view was incorrect. The questions were answered against the assessee and in favour of the department.

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