Cash-basis deduction must be allowed in the relevant year; Tribunal cannot spread admissible expenditure over later years.

Where agricultural income is computed under the assessee's regularly employed cash method, deductible expenditure must be allowed in the accounting year to which it relates. The statutory proviso permitting a different basis applies only when no regular method exists or the income cannot properly be deduced from that method. The Tribunal could not redistribute otherwise admissible expenditure over later years on fairness grounds, because the Act requires deduction in the relevant year and such apportionment would also prejudice the assessee's separate right to carry forward and set off loss. That portion of the Tribunal's order was therefore liable to be set aside in favour of the assessee.

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Issues: Whether, where the assessee maintained accounts on the cash basis, the admissible expenditure for the relevant accounting year could be apportioned by the Tribunal over subsequent years instead of being deducted in full in that year.

Analysis: The computation of agricultural income had to follow the method of accounting regularly employed by the assessee under the governing provision, and the proviso permitting a different basis applied only where no regular method existed or the income could not properly be deduced from the method employed. The deductible expenditure under the relevant deduction provision was expenditure laid out wholly and exclusively for deriving the agricultural income of the previous year, and therefore had to be given effect in the accounting year to which it related. The Tribunal had no authority to modify this statutory scheme merely on considerations of fairness. Such apportionment would also prejudice the assessee's separate statutory right to carry forward and set off any loss.

Conclusion: The Tribunal was not justified in spreading the admissible expenditure over later years, and that portion of its order was liable to be set aside in favour of the assessee.

Ratio Decidendi: Where income is computable under the regular cash method of accounting, expenditure deductible for that year must be allowed in that year itself, and an authority cannot redistribute that deduction over future years contrary to the Act.

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