In pari materia interpretation of agricultural income-tax provision followed earlier Income-tax Act construction in favour of the assessee.

Section 27(2) of the Kerala Agricultural Income-tax Act, 1950 was treated as in pari materia with section 184(2) of the Income-tax Act, 1961, so the same interpretation already accepted in favour of the assessee was applied. On that basis, the provision was construed consistently with the corresponding Income-tax Act provision, and the issue was answered against the Revenue and in favour of the assessee.

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Issues: Whether section 27(2) of the Kerala Agricultural Income-tax Act, 1950, being in pari materia with section 184(2) of the Income-tax Act, 1961, warranted the same interpretation as had already been adopted against the Revenue and in favour of the assessee.

Analysis: The governing provision under the Kerala Agricultural Income-tax Act was treated as materially identical to the corresponding provision under the Income-tax Act. Since the corresponding question had already been decided against the Revenue and in favour of the assessee, the same construction was applied to the present appeals.

Conclusion: The issue was answered in favour of the assessee and against the Revenue.

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